SEC Petition Evaluation Report
 

Petition SEC-00057-1 

Report Rev # _05-15-07 Report Submittal Date ______5/15/2007____ 

Subject Expert(s): James Berger 

Site Expert(s): N/A 

Petition Administrative Summary 

Petition Under Evaluation 

Petition # Petition 

Type 

Petition B 

Qualification Date 

DOE/AWE Facility Name 

SEC-00057-1 83.13 November 21, 2006 Hanford 

Petitioner Class Definition 

All employees in all facilities and areas of the Hanford Nuclear Reservation from January 1, 1942 through 

December 31, 1990. 

Proposed Class Definition 

All employees of the Department of Energy (DOE), its predecessor agencies, and DOE contractors and 

subcontractors, who were monitored, or should have been monitored, for internal radiological exposures while 

working at the Hanford Engineer Works in: the 300 Area fuel fabrication facilities from October 1, 1943 

through August 31, 1946; the 200 Area plutonium separation facilities from November 1, 1944 through August 

31, 1946; or the 100 B, D, and F reactor areas from September 1, 1944 through August 31, 1946; and who were 

employed for at least 250 aggregated work days either solely under their employment or in combination with 

work days within the parameters established for other SEC classes (excluding aggregate work day 

requirements). 

Related Petition Summary Information 

SEC Petition Tracking #(s) Petition Type DOE/AWE Facility Name Petition Status 

SEC-00050 83.13 Hanford Merged with SEC-00057 

Related Evaluation Report Information 

Report Title DOE/AWE Facility Name 

SEC-00057-2, 2nd Part of this Evaluation Report Hanford 

ORAU Lead Technical Evaluator: Albert W. Wolff ORAU Review Completed By: Dan Stempfley 

Peer Review Completed By: [Signature on file] 

Sam Glover 

05/17/2007 

Date 

SEC Petition Evaluation Reviewed By: [Signature on file] 

J. W. Neton 

5/18/2007 

Date 

SEC Evaluation Approved By: [Signature on file] 

Larry Elliott 

5/18/2007 

Date 
SEC-00057-1 05-15-07 FINAL Hanford 

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Evaluation Report Summary: SEC-00057-1, Hanford 

This evaluation report by the National Institute for Occupational Safety and Health (NIOSH) 

addresses a class of employees proposed for addition to the Special Exposure Cohort (SEC) per the 

Energy Employees Occupational Illness Compensation Program Act of 2000, as amended, 42 U.S.C. 

§ 7384 et seq. (EEOICPA) and 42 C.F.R. pt. 83, Procedures for Designating Classes of Employees as 

Members of the Special Exposure Cohort under the Energy Employees Occupational Illness 

Compensation Program Act of 2000. 

Petitioner-Requested Class Definition 

This petition reviews the requested class as follows: 

•	 Petition SEC-00050, qualified on November 9, 2006, requested that NIOSH consider the 

following class: All production workers in the 100 Area and 300 Area from January 1943 until 

September 1, 1946, and all 200 Area production workers and all guards and construction workers 

from December 1944 to September 1, 1946. 

•	 Petition SEC-00057, qualified on November 21, 2006, requested that NIOSH consider the 

following class: All employees in all facilities and areas of the Hanford Reservation from January 

1, 1942 to December 31, 1990. 

NIOSH-Proposed Class Definition 

NIOSH merged the two petitions because the class requested in SEC-00050 is encompassed by the 

class requested in SEC-00057. For evaluation purposes, due to the complexity of Hanford operations 

over almost fifty years, the SEC-00057 class and associated evaluation report was divided into two 

separate time periods. 

This report, SEC-00057-1, which defines a single class of employees for which NIOSH has 

determined it cannot estimate radiation doses with sufficient accuracy, covers the early years of the 

DuPont Company site operations from October 1, 1943 through August 31, 1946. The class for this 

report is defined as: All employees of the Department of Energy (DOE), its predecessor agencies, and 

DOE contractors and subcontractors, who were monitored, or should have been monitored, for 

internal radiological exposures while working at the Hanford Engineer Works in: the 300 Area fuel 

fabrication facilities from October 1, 1943 through August 31, 1946; the 200 Area plutonium 

separation facilities from November 1, 1944 through August 31, 1946; or the 100 B, D, and F reactor 

areas from September 1, 1944 through August 31, 1946; and who were employed for at least 250 

aggregated work days either solely under their employment or in combination with work days within 

the parameters established for other SEC classes (excluding aggregate work day requirements). 

The start dates for the class were chosen to coincide with the time periods when radioactive materials 

were used or created during DuPont-operated production in the specified areas. Uranium in the form 

of rods extruded off-site were first brought to Hanford in October 1943 and stored in the 300 Area 

(WHC-MR-0425). The first uranium machining operations began in December 1943. The first 

production reactor, 105-B, started operation in September 1944. Plutonium separation operations 

began with the first irradiated fuel being stored in the 200 North Area in November 1944. Prior to the 

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start of operations in these various facilities, Hanford Engineer Works construction was underway 

(WHC-MR-0425). 

A second evaluation report, SEC-00057-2, will evaluate the remaining SEC-00057 petitionerrequested years under various site operators (September 1, 1946 through December 31, 1990). 

Feasibility of Dose Reconstruction 

Per EEOICPA and 42 C.F.R. § 83.13(c)(1), NIOSH has determined that it does not have access to 

sufficient information to: (1) estimate the maximum radiation dose incurred by any member of the 

class; or (2) estimate radiation doses more precisely than a maximum dose estimate. Information 

available from the site profile and additional resources is not sufficient to document or estimate the 

maximum internal and external potential exposure to members of the proposed class under plausible 

circumstances during the specified period. 

Health Endangerment Determination 

Per EEOICPA and 42 C.F.R. § 83.13(c)(3), a health endangerment determination is required because 

NIOSH has determined that it does not have sufficient information to estimate dose for the members 

of the proposed class. 

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Table of Contents 

Evaluation Report Summary: SEC-00057-1, Hanford ............................................................................ 3
 

1.0 Purpose and Scope.......................................................................................................................... 9
 

2.0 Introduction .................................................................................................................................... 9
 

3.0 Petitioner-Requested Class/Basis & NIOSH-Proposed Class/Basis ............................................ 10
 

4.0 Data Sources Reviewed by NIOSH.............................................................................................. 12 

4.1 Site Profile Technical Basis Documents (TBDs) ................................................................ 12 

4.2 ORAU Technical Information Bulletins (OTIBs) and Procedures ..................................... 12 

4.3 Facility Employees and Experts .......................................................................................... 13 

4.4 Previous Dose Reconstructions ........................................................................................... 14 

4.5 NIOSH Site Research Database .......................................................................................... 14 

4.6 Comprehensive Epidemiologic Data Resource (CEDR) Database ..................................... 15 

4.7 Hanford Radiological Exposure (REX) Database ............................................................... 15 

4.8 Other Technical Sources...................................................................................................... 15 

4.9 Documentation and/or Affidavits Provided by Petitioners ................................................. 15
 

5.0 Radiological Operations Relevant to the Proposed Class ............................................................ 17 

5.1 Hanford Site Process Descriptions ...................................................................................... 17 

5.2 Hanford Functional Areas ................................................................................................... 20 

5.2.1 Fuel Fabrication ....................................................................................................... 20
 

5.2.2 Reactor Operation.................................................................................................... 21 

5.2.3 Chemical Separations .............................................................................................. 21 

5.3 Radiological Exposure Sources from Hanford Operations ................................................. 26 

5.3.1 Alpha Particle Emissions......................................................................................... 26 

5.3.2 Beta Radiation Fields .............................................................................................. 26 

5.3.3 Neutron Exposures .................................................................................................. 27 

5.3.4 Photon Exposures .................................................................................................... 27 

5.3.5 Incidents and Fires................................................................................................... 27
 

6.0 Summary of Available Monitoring Data for the Proposed Class ................................................. 28 

6.1 Hanford Internal Monitoring Data....................................................................................... 28 

6.2 Hanford External Monitoring Data ..................................................................................... 29 

6.3 Hanford Air Sampling Data................................................................................................. 30
 

7.0 Feasibility of Dose Reconstruction for the Proposed Class ......................................................... 31 

7.1 Pedigree of Hanford Data.................................................................................................... 32 

7.1.1 Internal Data Review............................................................................................... 32 

7.1.2 External Data Review.............................................................................................. 32 

7.2 Internal Radiation Doses at Hanford ................................................................................... 33 

7.2.1 Process-Related Internal Doses at Hanford ............................................................. 33 

7.2.2 Ambient Environmental Internal Radiation Doses at Hanford ............................... 33 

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7.2.3 Internal Dose Reconstruction .................................................................................. 34 

7.2.4 Internal Dose Reconstruction Feasibility Conclusion ............................................. 34 

7.3 External Radiation Doses at Hanford .................................................................................. 35 

7.3.1 Process-Related External Radiation Doses at Hanford ........................................... 35 

7.3.1.1 Radiation Exposure Environment............................................................. 35 

7.3.1.2 History of Whole Body External Monitoring........................................... 36 

7.3.1.3 History of Extremity Monitoring.............................................................. 37 

7.3.1.4 History of Neutron Monitoring ................................................................ 37 

7.3.1.5 Dosimetry Records ................................................................................... 37 

7.3.1.6 Application of Co-Worker Data for External Dose Reconstruction ........ 38 

7.3.2 Ambient Environmental External Radiation Doses at Hanford .............................. 38 

7.3.2.1 Ambient Radiation.................................................................................... 39 

7.3.2.2 Releases of Noble Gases .......................................................................... 39 

7.3.2.3 Skin Deposition of Airborne Particulate Emissions ................................. 39 

7.3.3 Hanford Occupational X-Ray Examinations ........................................................... 39 

7.3.4 External Dose Reconstruction ................................................................................. 40 

7.3.4.1 Photon and Electron Dose ........................................................................ 40 

7.3.4.2 Neutron Dose ............................................................................................ 41 

7.3.4.3 Unmonitored Individuals Working in Production Areas.......................... 42 

7.3.4.4 Medical X-ray........................................................................................... 42 

7.3.5 External Dose Reconstruction Feasibility Conclusion ............................................ 42 

7.4 Evaluation of Petition Basis for SEC-00057-1.................................................................... 43 

7.4.1 Evaluation of Major Topics Detailed in Petition SEC-00057-1.............................. 43 

7.4.1.1 Missing Hanford DuPont Area Dosimetry Records ................................. 43 

7.4.1.2 Method Used to Estimate Releases Not Claimant Favorable................... 43 

7.4.1.3 Under-recording of Neutron Dose ............................................................ 44 

7.6 Summary of Feasibility Findings for Petition SEC-00057-1 .............................................. 44
 

8.0 Evaluation of Health Endangerment for Petition SEC-00057-1 .................................................. 45
 

9.0 NIOSH-Proposed Class for Petition SEC-00057-1 ...................................................................... 45
 

10.0 References .................................................................................................................................... 47 

Figure 

Figure 5-1: Hanford Site Operations Areas, 1943-1946 ....................................................................... 19 

Tables 

Table 4-1: Number of Hanford Claims Submitted Under the Dose Reconstruction Rule .................... 14
 

Table 5-1: Hanford Site Development Chronology ............................................................................. 18 

Table 5-2: Key Hanford Site Facilities and Operations (1943 through August 1946).......................... 25 

Table 5-3: Principal Site Alpha-Emitting Radionuclides ..................................................................... 26 

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Table 5-4: Hanford Site Beta-Emitting Radionuclides ........................................................................ 26
 

Table 6-1: Summary Statistics of Monitoring Data for Hanford (1944-1946) ..................................... 30 

Table 6-2: Hanford Air Sampling Data ................................................................................................. 31
 

Table 7-1: Annual Intakes of Particulate Radionuclides ....................................................................... 34
 

Table 7-2: Default Beta and Photon Energies/Percentages for Hanford DuPont Operations ............... 35 

Table 7-3: Summary of Feasibility Findings for SEC-00057-1 ............................................................ 44 

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SEC Petition Evaluation Report for SEC-00057-1
 

1.0 Purpose and Scope 

ATTRIBUTION AND ANNOTATION: This is a single-author document. All conclusions drawn from 

the data presented in this evaluation were made by the ORAU Team Lead Technical Evaluator: Albert 

W. Wolff, Oak Ridge Associated Universities. These conclusions were peer-reviewed by the 

individuals listed on the cover page. The rationales for all conclusions in this document are explained 

in the associated text. 

This report evaluates the feasibility of reconstructing doses for all employees, contractors, and 

subcontractors of the DOE, and its predecessor agencies, who were monitored, or should have been 

monitored, for radiological exposures while working at the Hanford Engineer Works in: the 300 Area 

fuel fabrication facilities from October 1, 1943 through August 31, 1946; the 200 Area plutonium 

separation facilities from November 1, 1944 through August 31, 1946; or the 100 B, D, and F reactor 

areas from September 1, 1944 through August 31, 1946. It provides information and analyses 

germane to considering a petition for adding a class of employees to the congressionally-created SEC. 

This report does not make any determinations concerning the feasibility of dose reconstruction that 

necessarily apply to any individual energy employee who might require a dose reconstruction from 

NIOSH. This report also does not contain the final determination as to whether the proposed class 

will be added to the SEC (see Section 2.0). 

This evaluation was conducted in accordance with the requirements of EEOICPA, 42 C.F.R. pt. 83, 

and the guidance contained in the Office of Compensation Analysis and Support’s (OCAS) Internal 

Procedures for the Evaluation of Special Exposure Cohort Petitions, OCAS-PR-004. 

2.0 Introduction 

Both EEOICPA and 42 C.F.R. pt. 83 require NIOSH to evaluate qualified petitions requesting that the 

Department of Health and Human Services (HHS) add a class of employees to the SEC. The 

evaluation is intended to provide a fair, science-based determination of whether it is feasible to 

estimate with sufficient accuracy the radiation doses of the class of employees through NIOSH dose 

reconstructions.1 

42 C.F.R. § 83.13(c)(1) states: Radiation doses can be estimated with sufficient accuracy if NIOSH 

has established that it has access to sufficient information to estimate the maximum radiation dose, 

for every type of cancer for which radiation doses are reconstructed, that could have been incurred in 

plausible circumstances by any member of the class, or if NIOSH has established that it has access to 

sufficient information to estimate the radiation doses of members of the class more precisely than an 

estimate of the maximum radiation dose. 

1

 NIOSH dose reconstructions under EEOICPA are performed using the methods promulgated under 42 C.F.R. pt. 82 and 

the detailed implementation guidelines available at http://www.cdc.gov/niosh/ocas. 

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Under 42 C.F.R. § 83.13(c)(3), if it is not feasible to estimate with sufficient accuracy radiation doses 

for members of the class, NIOSH must also then determine whether or not there is a reasonable 

likelihood that such radiation doses may have endangered the health of members of the class. The 

regulation requires NIOSH to assume that any duration of unprotected exposure may have endangered 

the health of members of a class when it has been established that the class may have been exposed to 

radiation during a discrete incident likely to have involved levels of exposure similarly high to those 

occurring during nuclear criticality incidents. If the occurrence of such an exceptionally high-level 

exposure has not been established, then NIOSH is required to specify that health was endangered for 

those workers who were employed for at least 250 aggregated work days within the parameters 

established for the class or in combination with work days within the parameters established for other 

SEC classes (excluding aggregate work day requirements). 

NIOSH is required to document its evaluation in a report, and to do so, relies upon both its own dose 

reconstruction expertise as well as technical support from its contractor, Oak Ridge Associated 

Universities (ORAU). Once completed, NIOSH provides the report to both the petitioner(s) and to the 

Advisory Board on Radiation and Worker Health (Board). The Board will consider the NIOSH 

evaluation report, together with the petition, petitioner(s) comments, and other information the Board 

considers appropriate, in order to make recommendations to the Secretary of HHS on whether or not 

to add one or more classes of employees to the SEC. Once NIOSH has received and considered the 

advice of the Board, the Director of NIOSH will propose a decision on behalf of HHS. The Secretary 

of HHS will make the final decision, taking into account the NIOSH evaluation, the advice of the 

Board, and the proposed decision issued by NIOSH. As part of this decision process, petitioners may 

seek a review of certain types of final decisions issued by the Secretary of HHS.2 

3.0 Petitioner-Requested Class/Basis & NIOSH-Proposed Class/Basis 

Two petitions associated with the Hanford Site requested that NIOSH consider classes for addition to 

the SEC: 

•	 Petition SEC-00050, qualified on November 9, 2006, requested that NIOSH consider the 

following class: All production workers in the 100 Area and 300 Area from January 1943 until 

September 1, 1946, and all 200 Area production workers and all guards and construction workers 

from December 1944 to September 1, 1946. 

•	 Petition SEC-00057, qualified on November 21, 2006, requested that NIOSH consider the 

following class: All employees in all facilities and areas of the Hanford Reservation from January 

1, 1942 to December 31, 1990. 

The petitioners provided information and affidavit statements in support of the petitioner’s belief that 

accurate dose reconstruction over time is impossible for the Hanford workers in question. NIOSH 

deemed the following information and affidavit statements sufficient to qualify SEC-00057-1 for 

evaluation: 

2 See 42 C.F.R. pt. 83 for a full description of the procedures summarized here. Additional internal procedures are 

available at http://www.cdc.gov/niosh/ocas. 

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The SEC-00057 petitioner claimed that personal monitoring data gaps existed for several of 

the individual workers listed in the petition. NIOSH found that the monitoring gap 

information provided by the petitioner did not support the submission basis for qualifying 

the petition. However, during the qualifying process, NIOSH identified some pre-1946 

operational periods for which no internal exposure monitoring was performed. NIOSH 

qualified SEC-00057 on this basis. 

Petition SEC-00050 was qualified based on being completely encompassed by Petition 

SEC-00057. 

The information and statements provided by the petitioner qualified the petition for further 

consideration by NIOSH, the Board, and HHS. The details of the petition basis are addressed in 

Section 7.4. 

NIOSH merged the two petitions because the class requested in SEC-00050 is encompassed by the 

class requested in SEC-00057. For evaluation purposes, due to the complexity of Hanford operations 

over almost fifty years, the SEC-00057 class and associated evaluation report was divided into two 

separate time periods. This report (SEC-00057-1) defines a single class of employees for which 

NIOSH cannot estimate radiation doses with sufficient accuracy. 

This report, SEC-00057-1, covers the early years of the DuPont Company site operations from 

October 1, 1943 through August 31, 1946. The class for this report is defined as: All employees of 

the DOE or DOE contractors or subcontractors who were monitored, or should have been monitored, 

for radiological exposures while working at the Hanford Engineer Works in: the 300 Area fuel 

fabrication facilities from October 1, 1943 through August 31, 1946; the 200 Area plutonium 

separation facilities from November 1, 1944 through August 31, 1946; or the 100 B, D, and F reactor 

areas from September 1, 1944 through August 31, 1946; and who were employed for at least 250 

aggregated work days either solely under their employment or in combination with work days within 

the parameters established for other SEC classes (excluding aggregate work day requirements). The 

class was modified as a result of the feasibility evaluation documented in Section 7.0. 

NIOSH modified the petitioner-requested class to define a single class of employees for which 

NIOSH cannot estimate radiation doses with sufficient accuracy. The start dates for the class coincide 

with the time periods when radioactive materials were present or used during DuPont-operated 

production in the specified areas. Uranium in the form of rods (extruded off-site) were first brought to 

Hanford in October 1943 and stored in the 300 Area. The first uranium machining operations began 

in December 1943. The first production reactor, 105-B, started operation in September 1944. 

Plutonium separation operations began with the first irradiated fuel being stored in the 200 Area in 

November 1944. Prior to the start of these radiological operations, Hanford Engineer Works 

personnel were engaged in non-radiological activities associated with site construction and project 

preparations (WHC-MR-0425). 

A second evaluation report, SEC-00057-2, will cover the remaining SEC-00057 petitioner-requested 

years under various site operators (September 1, 1946 through December 31, 1990). 

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4.0 Data Sources Reviewed by NIOSH 

NIOSH identified and reviewed numerous data sources determine information relevant to determining 

the feasibility of dose reconstruction for the class of employees proposed for this petition. This 

included determining the availability of information on personal monitoring, area monitoring, 

industrial processes, and radiation source materials. The following subsections summarize the data 

sources identified and reviewed by NIOSH. 

4.1 Site Profile Technical Basis Documents (TBDs) 

A Site Profile provides specific information concerning the documentation of historical practices at 

the specified site. Dose reconstructors can use the Site Profile to evaluate internal and external 

dosimetry data for monitored and unmonitored workers, and to supplement, or substitute for, 

individual monitoring data. A Site Profile consists of an Introduction and five Technical Basis 

Documents (TBDs) that provide process history information, information on personal and area 

monitoring, radiation source descriptions, and references to primary documents relevant to the 

radiological operations at the site. The Site Profile for a small site may consist of a single document. 

As part of NIOSH’s evaluation detailed herein, it examined the following TBDs for insights into 

Hanford operations or related topics/operations at other sites: 

• Technical Basis Document for the Hanford Site – Introduction 

ORAUT-TKBS-0006-1; Rev. 02; August 30, 2006; SRDB Ref ID: 31193 

• Technical Basis Document for the Hanford Site – Site Description 

ORAUT-TKBS-0006-2; Rev. 00 PC-1; December 29, 2004; SRDB Ref ID: 19489 

• Technical Basis Document for the Hanford Site – Occupational Medical Dose 

ORAUT-TKBS-0006-3; Rev. 01; April 11, 2005; SRDB Ref ID: 19491 

• Technical Basis Document for the Hanford Site – Occupational Environmental Dose 

ORAUT-TKBS-0006-4; Rev. 01; December 20, 2006; SRDB Ref ID: 31194 

• Technical Basis Document for the Hanford Site – Occupational Internal Dose 

ORAUT-TKBS-0006-5; Rev. 01; November 24, 2004; SRDB Ref ID: 19494 

• Technical Basis Document for the Hanford Site – Occupational External Dose 

ORAUT-TKBS-0006-6; Rev. 02; November 21, 2006; SRDB Ref ID: 29989 

4.2 ORAU Technical Information Bulletins (OTIBs) and Procedures 

An ORAU Technical Information Bulletin (OTIB) is a general working document that provides 

guidance for preparing dose reconstructions at particular sites or categories of sites. An ORAU 

Procedure provides specific requirements and guidance regarding EEOICPA project-level activities, 

including preparation of dose reconstructions at particular sites or categories of sites. NIOSH 

reviewed the following OTIBs and procedures as part of its evaluation: 

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•	 OTIB: External Coworker Dosimetry Data for the Hanford Site, ORAUT-OTIB-0030; Rev. 00 

PC-1; November 7, 2006; SRDB Ref ID: 29961 

•	 OTIB: Internal Coworker Dosimetry Data for the Hanford Site, ORAUT-OTIB-0039; Rev. 00 

PC-2; January 31, 2007; SRDB Ref ID: 29969 

•	 OTIB: Fission and Activation Product Assignment for Internal Dose-Related Gross Beta and 

Gross Gamma Analyses, ORAUT-OTIB-0054 (Draft - January 18, 2007); SRDB Ref ID: Under 

OCAS review 

•	 PROC: Occupational Onsite Ambient Dose Reconstruction for DOE Sites, ORAUT-PROC-0060, 

Rev. 01; June 28, 2006; SRDB Ref ID: 29986 

•	 PROC: Occupational X-Ray Dose Reconstruction for DOE Sites, ORAUT-PROC-0061, Rev. 01; 

July 21, 2006; SRDB Ref ID: 29987 

4.3 Facility Employees and Experts 

To obtain additional information, NIOSH conducted telephone interviews with eleven former site 

employees specializing in radiation protection. None of these workers had been employed during the 

DuPont years; however, they provided insight into the availability of records, personal monitoring, the 

Health Instrument Group program, work practices, and other issues related to this evaluation. The 

interviewees were also asked if they were aware of any other Hanford radiation protection personnel 

workers employed during the DuPont years who were available for interviews; none were identified. 

The following resources were reviewed for any pertinent information regarding the class of employees 

covered by this evaluation: 

•	 SCA-TR-TASK1-0004, Review of NIOSH Site Profile for the Hanford Site, Richland, 

Washington; Site Expert Interviews, Att. 3, 4, and 5; S. Cohen & Associates; OCAS website: 

http://www.cdc.gov/niosh/ocas/hanford.html 

•	 Worker Outreach Meeting with Central Washington Building and Construction Trades Council, 

AFL-CIO, January 13, 2004; OCAS website: http://www.cdc.gov/niosh/ocas/hanford.html 

•	 Worker Outreach Meeting with Hanford Atomic Metal Trades Council, AFL-CIO (HAMTC), 

January 14, 2004; OCAS website: http://www.cdc.gov/niosh/ocas/hanford.html 

•	 Worker Outreach Meeting with Paper, Allied-Industrial, Chemical and Energy Workers (PACE) 

Local #8-0369, April 22, 2004; OCAS website: http://www.cdc.gov/niosh/ocas/hanford.html 

•	 Worker Outreach Meeting with DuPont Era Workers, March 28, 2007; Not yet on OCAS website: 

http://www.cdc.gov/niosh/ocas/hanford.html 

•	 Notes from telephone interviews with eleven former Hanford Radiation Protection workers; 

SECIS ID: SEC00057, Non-submitter Communication ID: 135 

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4.4 Previous Dose Reconstructions 

NIOSH reviewed its NIOSH OCAS Claims Tracking System (NOCTS) to locate EEOICPA-related 

dose reconstructions that might provide information relevant to the petition evaluation. Table 4-1 

summarizes the results of this review for the period of January 1, 1942 through August 31, 1946. 

(NOCTS data available as of April 20, 2007) 

Table 4-1: Number of Hanford Claims Submitted Under the Dose Reconstruction Rule 

(January 1, 1942 through August 31, 1946) 

Description Totals 

Total number of claims submitted for energy employees who meet the proposed class definition 

criteria 378 

Number of dose reconstructions completed for energy employees who were employed during the 

years identified in the proposed class definition 328 

Number of claims for which internal dosimetry records were obtained for the identified years in the 

proposed class definition (see explanation below) 49 

Number of claims for which external dosimetry records were obtained for the identified years in the 

proposed class definition 244 

NIOSH reviewed each claim to determine whether internal and/or external personal monitoring 

records could be obtained for the employee. As indicated in Table 4-1, NIOSH has been able to 

obtain external monitoring data for a majority of the claims that meet the proposed class definition. 

Of the total number of claims submitted, 244 (65%) have external monitoring data available. 

Although there were 49 claims (13%) that had internal monitoring data, the internal dosimetry 

program was in its infancy during the time period of this class. The Hanford bioassay group was not 

founded until the early part of 1946 and early results were erratic with poor yields and poor process 

control. Even though there were approximately 500 assays done, many of the difficulties were not 

solved until August 1946, which is the final month of the class covered by this evaluation. 

(PNL-6125). 

The dose reconstruction claimant interviews provided some information that is useful for dose 

reconstruction, such as work locations, hours worked, incidents, and hazards encountered. The 

interviews also identified conditions for which there would have been a potential for internal 

exposures. 

4.5 NIOSH Site Research Database 

NIOSH also examined its Site Research Database to locate documents supporting the evaluation of 

the proposed class. Six hundred seventy seven documents in this database were identified as 

pertaining to the Hanford site. A smaller number of documents (42) were written during the DuPont 

years. These documents were evaluated for their relevance to this petition. The documents include 

historical background on process descriptions, site history, Hanford Engineer Works monthly reports, 

Health Instrument Section monthly reports, incident documentation, and epidemiological studies. 

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4.6 Comprehensive Epidemiologic Data Resource (CEDR) Database 

NIOSH searched the CEDR database for available internal and external monitoring data. 

4.7 Hanford Radiological Exposure (REX) Database 

NIOSH searched the REX database (maintained by the Hanford Site) for available internal and 

external monitoring data. 

4.8 Other Technical Sources 

Herbert M. Parker: Publications and Other Contributions to Radiological and Health Physics; 

Kathren, R., et al (editors); Columbus [Ohio]: Battelle Press, 1986; SRDB Ref ID: 27678 

4.9 Documentation and/or Affidavits Provided by Petitioners 

In qualifying and evaluating the two Hanford petitions, NIOSH reviewed the following documents 

submitted by the petitioners: 

Note: Some documents submitted by petitioners pertain to the later years of Hanford operations. 

Only documents pertaining to the class being evaluated by this report are included on this list. 

Petition SEC-00050: 

•	 Technical Services Division Monthly Report, HW-17410; March 1950; SECIS Ref ID: 9425 

•	 Report for the In Re Berg Litigation Reference-Hanford Releases, K. G. McNeill and R.E. Jervis, 

University of Toronto; March 1, 1999; SECIS Ref ID: 9425 

•	 Errors in HEDR I-131 Release Estimates and Corrections to Dose Estimates to Account For 

These Errors, Report to the Hanford Radiation Litigation, Tom H. Foulds and Richard Eymann, 

Attorneys; K. G. McNeill and R.E. Jervis, University of Toronto; March 2004; SECIS Ref ID: 

9425 

•	 Source Term Task Responses (September 9, 1994) to EPRP Outstanding Issues Cited in June 17, 

1994 FAX, Carter to Shipler, Letter from A. G. Blasewitz to Dr. Melvin W. Carter, September 22, 

1994, SECIS Ref ID: 9425 

•	 Stack Contamination - 200 Area, Report from J. P. Martel to C. N. Gross, Page 8; August 6, 1948; 

SECIS Ref ID: 9425 

•	 Use of Natural Airborne Radioactivity to Evaluate Filters for Alpha Air Sampling, C. L. Lindeken; 

Industrial Hygiene Journal; August 1961, SECIS Ref ID: 9425 

•	 Notes of Interview with Bernard Saueressig on 8/15/96, Signed by Bernard Saueressig; October 7, 

1996; SECIS Ref ID: 9425 

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•	 Reconstructing Hanford Past Releases of Radioactive Materials: The History of the Technical 

Steering Panel 1988-1995; November 1996; SECIS Ref ID: 9425
 

•	 Atmospheric Diversion and Deposition of I-131 Released from the Hanford Site, Ramsdell et al; 

Health Physics, Volume 71, Number 4; October 1996; SECIS Ref ID: 9425 

•	 Videotape Deposition of John Till, Ph.D., United States District Court, Eastern District of 

Washington, Master File, No. CY-91-3015-WFN; November 19, 2004; SECIS Ref ID: 9425 

•	 Regional Atmospheric Transport Code for Hanford Emission Tracking (RATCHET), PNWD-2224 

HEDR; Ramsdell, J. V., Jr., et al; February 1994; SECIS Ref ID: 9425 

•	 Hanford Cohort Study 1989, and 1993, Further Description of the Hierarchical Organization of 

CEDR Structured Documentation, SECIS Ref ID: 9573 

•	 Affidavit of Cathie J. Boyer, United States District Court, Western District of Washington, Master 

File, No. CY-91-3015-AAH; May 1994; SECIS Ref ID: 9573 

•	 Status of Document Search and Data Quality Objective Efforts, PNWD-204; Gydesen, S. P.; 

Hanford Environmental Dose Reconstruction Project; October 1992; SECIS Ref ID: 9573 

•	 Estimation of the Pu-239 Releases to the Atmosphere from the Hanford Site, Report to Tom H. 

Foulds, Hanford Litigation Office, Seattle; Klementiev, A. A.; December 21, 1995; SECIS Ref ID: 

9573 

•	 Hanford Litigation-HEDR Vegetation Radiation Model Comparison, Prepared for Tom H. Foulds
 

and Associated Counsel for the Hanford Radiation Litigation, The, Jesse L, Ph.D.; P. Eng.; Lake 

Environmental Consultants, Inc.; February 26, 1999; SECIS Ref ID: 9573 

•	 A Re-Evaluation of the I-131 Atmospheric Releases from the Hanford Site, Napier, B. A.; Health 

Physics, Vol 83, Number 2; August 2002; SECIS Ref ID: 9573 

•	 Hanford’s Air Monitoring Program From 1945-1955 - A Compilation of Notes, Letter to File, 

Mart, E.I.; February 10, 1988; SECIS Ref ID: 9573 

•	 Description of the Process Used to Create 1992 Hanford Mortality Study Database, PNL-8449; 

Gilbert, E. S., et al; December 1992; SECIS Ref ID: 9601 

•	 A Guide to Environmental Monitoring Data, 1945-1972, PNWD-2226 HEDR; Thiede, M. E., et 

al; Hanford Environmental Dose Reconstruction Project; March 1994; SECIS Ref ID: 9601 

•	 Environmental Radiological Monitoring of Air, Rain, and Snow on and near the Hanford Site, 

1945-1957; R. W. Hanf, M. E. Thiede; PNWD-2234 HEDR; March 1994; SECIS Ref ID: 9601 

Petition SEC-00057: 

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•	 Collection of letters, memoranda, records of conversations, meeting notes, personal logbooks, 

court records, and depositions related to the SEC-00050 petitioners’ allegations that the HEDR 

Study was biased; SECIS Ref ID: 9652 

•	 Potential Unrecorded Neutron Dose, Letter to distribution; Jack J. Fix; August 27, 1997; SECIS 

Ref ID: 9959 

•	 Eleven affidavits submitted by the SEC-00057 petitioner regarding missing dosimetry records, 

location of records, medical conditions of individual workers, incidents, and overexposures; 

SECIS Ref ID: 9959 

•	 Vern Haugen’s Handwritten Diary; June 6, 2006; SECIS Ref ID: 9959 

5.0 Radiological Operations Relevant to the Proposed Class 

The following subsections summarize both radiological operations at the Hanford Site from January 

1943 to August 31, 1946, and the information available to NIOSH to characterize particular processes 

and radioactive source materials. From available sources NIOSH has gathered process and source 

descriptions, information regarding the identity and quantities of each radionuclide of concern, and 

information describing both processes through which radiation exposures may have occurred and the 

physical environment in which they may have occurred. The information included within this 

evaluation report is intended only to be a summary of the available information. Radiological 

operations are discussed in more detail in Section 5.2. 

5.1 Hanford Site Process Descriptions 

In 1943, the U.S. Army Corp of Engineers selected an area of approximately 600 square miles along 

the Columbia River in south-central Washington for the production of plutonium and other nuclear 

materials to support weapons production for World War II. This area, now known as the Hanford 

Site, was divided into three major operational areas, each located and designed specifically for its role 

in plutonium production. The 100 Areas handled production reactor operations; the 200 Areas 

handled fuel reprocessing, plutonium recovery, and waste management; and the 300 Area handled fuel 

fabrication and general research and development activities. To assure continuing capacity in case of 

maintenance downtime, emergencies, and sabotage, many major Hanford plutonium production 

operations were duplicated. They were also essentially self-sufficient, containing all necessary 

support services and facilities. Figure 5-1 shows the locations of these major operational areas. 

There were other Hanford Areas, but they had little, if any, involvement with radioactive material 

operations. The 600 Area was the general category assigned to facilities that were located outside the 

security boundaries of major areas, and supported multiple operations. Such operations included road 

systems, fire stations, environmental and weather monitoring stations, and Nike Missile sites. Some 

300 Area waste burial sites, which were located outside the 300 Area fence, were also included in the 

600 Area designation. The 700 Area was located inside the community of Richland and consisted of 

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administration, central supply, laundry, and repair/maintenance services. Richland Village was 

designated the 1100 Area, and the Richland Construction Camp was the 3000 Area. 

Construction of facilities for plutonium production began almost immediately in 1943 and production 

operations were underway by the end of 1944. During 1944 and 1945, additional facilities were 

constructed to increase production. Research and development on reactor materials and technology 

and on biological and ecological effects of radiation were also started during this time. Table 5-1 

summarizes Hanford Site development from 1943 through August 31, 1946. Section 5.2.7 provides a 

summary of key Hanford Site facilities. Additional information regarding the design and operation of 

the major facilities is presented in Sections 5.2.1 through 5.2.6. 

Table 5-1: Hanford Site Development Chronology 

Years Areas Comments Plant Population 

1943 All areas Construction started in March Construction 30,459 

300 Start-up of 305 test reactor and 313 fuel fabrication 

1944 All Construction continues Construction 43,019 

100 Start-up of B reactor and D reactor Operating 5,289 

200 Start-up of T Plant (221/224); construction of 64 storage tanks 

begins 

300 Fuel canning started in 313; 314 fuels building start-up 

1945 All Initial construction activities completed Construction 343 

100 Start-up of F reactor Operating 6,099 

200 

Start-up of B Plant (221/224); U Plant completed but only used for 

training and developing procedures and equipment for T and B 

Plants; plutonium finishing operations begin in 231-Z; 

construction of 64 storage tanks completed 

300 3706 Radiochemistry Building and 321 cold semi-works start-up 

1946 All areas Minimal construction or start-up of new facilities; emphasis on 

plutonium production operations and research on radiation effects 

Construction 403 

Operating 4,662 

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Figure 5-1: Hanford Site Operations Areas, 1943-1946 

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5.2 Hanford Functional Areas 

Hanford operations during the period of 1943 through August 31, 1946 included the following major 

functional areas: 

• Fuel Fabrication 

• Reactor Operations 

• Fuel Reprocessing 

• Plutonium Finishing 

• Research and Development 

• Tank Farms and Waste Management 

The primary mission of early Hanford operations was production of plutonium and other nuclear 

materials to support weapons production. Operations developed, changed, and expanded to satisfy 

changing U.S. defense needs and to further the development of nuclear knowledge and technology. 

Additional information regarding the functional areas of the Hanford Site can also be found in 

ORAUT-TKBS-0006. 

5.2.1 Fuel Fabrication 

Plutonium was produced by irradiation of uranium metal fuel in the Hanford Site reactors. The fuel 

for these reactors was fabricated in the 300 Area. Initially, natural uranium rods extruded to the 

required size were obtained from other sites and employed as feed material for machining and canning 

operations in the Metal Fuel Fabrication Building (313). Beginning in 1945, uranium was obtained in 

billets and extruded to size in the Metal Extrusion Building (314). Upon receipt, uranium rods and 

billets were stored in the 303 Buildings, where they were inventoried and inspected. 

When beginning with uranium billets, the initial step in fuel fabrication consisted of preheating the 

billets in a furnace and extruding the uranium into rods. The rods were then heated in an argon 

atmosphere to drive off occluded gases. Rods were then straightened, if necessary. In the 313 

Building, rods were cut to the desired length by turret lathe and then machine-finished into slugs. 

Slugs were inspected and degreased in a nitric acid solution. Slugs were then heated by immersion in 

molten baths and inserted into thin aluminum cans. This heating process was known as the triple-dip 

process. After the uranium slug was inserted into the aluminum can, an aluminum cap was welded in 

place. Bonds and welds were inspected and tested. The finished fuel elements, measuring 1.5 inches 

in diameter and 8 inches in length, were inspected and tested in 305 Building and then transferred and 

stored in the 100 Areas until undergoing irradiation in reactors. 

Chips, turnings, and other solid scrap uranium were salvaged and pressed into briquettes. Liquids 

were settled and filtered to collect fines. Dusts and fines were burned to convert them to oxide form 

(DOE/RL-97-1047, page 2). These reclaimed uranium wastes were shipped offsite for recycling. 

Reviewed documents did not mention the occurrence of fires during the fuel fabrication operations. 

Based on the history of other fuel fabrication operations (which entail machining of uranium metal), it 

is unlikely that such fires occurred. 

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5.2.2 Reactor Operation 

Construction of three reactors (B, D, and F) to produce plutonium-239 by neutron irradiation of 

uranium-238 fuel elements started 1943. In September 1944, the first reactor (B) began operation. 

Start-up of D and F reactors occurred in December 1944 and February 1945. The selected design was 

a water-cooled, graphite-moderated pile with boron control rods. A typical reactor consisted of a 

large graphite block, approximately 36 feet by 36 feet by 28 feet, containing 2004 horizontal tubes for 

aluminum-clad natural uranium fuel elements. The block was surrounded by 8-10 inches of iron and 

40-80 inches of reinforced concrete shielding. The assembly contained multiple lines for cooling 

water and gas systems. 

These production reactors were located in the 100 Areas along the Columbia River. This location 

enabled access to large volumes of cooling water and achieved maximum distance from populated 

areas. Each reactor was located in its own complex, occupying approximately 1 square mile, and 

separated from other reactors by 1-3 miles to reduce the impact of possible malfunctions and sabotage. 

Reactors were located in buildings numbered105-B, 105-D, and 105-F, each measuring approximately 

250 feet by 230 feet by 95 feet high. Also located in each 105 Building were the control room, spent 

fuel discharge area, fuel storage, and associated handling equipment. Each reactor complex included 

approximately 30 support buildings and facilities and essentially operated independently of the others. 

With a reactor in the shutdown state, fresh fuel elements were loaded (“charged”) into fuel tubes at the 

face of the graphite block. As new elements were introduced, irradiated elements were pushed out of 

the back of the block, falling into a pool of water. Typically, about 25% of the fuel tubes were 

replaced at any one time. Irradiated fuel elements were allowed to cool in the pool to reduce radiation 

levels. Using remote handling tools, the elements were then loaded under 20 feet of water into large 

buckets (approximately 1000 pounds/bucket). After a further cooling period of 30 days, the buckets 

of spent fuel elements were transferred to the cooling basin where they awaited placement into shield 

casks and shipment to the 200 Areas for separation. 

Each reactor complex included facilities for managing its own waste. Single-pass cooling water was 

pumped to retention basins. The liquids were released from the retention basins into the Columbia 

River or into soil columns. There were designated sites for burial of solid radioactive waste. 

Reactors had associated high levels of direct gamma and neutron radiation during operations, and high 

gamma levels during shutdown conditions and spent fuel handling. There were potentials for worker 

exposures to surface and airborne contamination, in particular from fuel element failures. Monitoring 

of direct radiation was performed using fixed and portable systems, and workers wore personal 

monitoring devices. In potentially-contaminated areas, personnel protective clothing was worn, air 

monitoring was performed, and contamination monitors were provided. There were restrictions on 

eating and smoking in radiologically-contaminated areas. 

5.2.3 Chemical Separations 

Irradiated fuel elements were transported by rail in shielded casks from the 100 (reactor) Areas to the 

chemical separation plants in the 200 Areas. They were transported approximately half way to the 

separations facilities, where the elements were stored for up to 40 days in cooling basins in Buildings 

212-N, 212-P, and 212-R to allow for decay of short-lived radionuclides. After cooling, the fuel 

elements were reloaded into the casks for the remainder of the journey. 

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The first of three separations plants, called the T Plant, began operation in December 1944. B Plant 

start-up occurred in April 1945. The U Plant was constructed during the time period of the proposed 

class, but was never used for plutonium separations; instead, it was used for training and 

decontamination and repair of equipment from the T and B Plants. Each plant included a separations 

building (221 Building) and a reduction building (224 Building). These plants were large rectangular 

reinforced concrete structures. They consisted of a gallery area containing piping, electrical, and 

operational facilities, and a process canyon, below which was chemical separations equipment. 

Dimensions were approximately 810 feet by 85 feet by 102 feet high (approximately 20 feet of the 

height was below grade. T-Plant had an extra section about 65 feet in length. As with other major 

production facilities at Hanford, each chemical separations area included all the buildings and support 

services required to function as a self-sufficient operation. There were nine buildings and 19 service 

facilities in 200 North Area, 60 buildings and 33 service facilities in 200 East Area, and 48 buildings 

and 29 service facilities in 200 West Area. 

The plutonium chemical separations process used in the T and B Plants was known as the bismuth 

phosphate batch process. Three buckets of irradiated fuel elements were emptied into the dissolver 

tank in the Building 221 canyon, and the dissolver cell lid was replaced. A caustic solution was 

introduced into the tank and the aluminum cladding was dissolved from the fuel elements. After the 

decladded elements were rinsed, the fuel elements were dissolved in nitric acid. Bismuth phosphate 

was then added to precipitate plutonium as plutonium nitrate. Precipitation and centrifugation were 

repeated until the plutonium nitrate was thoroughly separated from the uranium, fission products, and 

impurities. At this stage, the plutonium nitrate was in a batch of approximately 330 gallons. This 

batch was next transferred to Building 224 (Bulk Reduction), where the 330 gallons was concentrated 

to approximately 8 gallons of plutonium nitrate paste, and further precipitations with hydrogen 

fluoride and lanthanum salts removed additional impurities. The plutonium nitrate paste was then 

transferred to the Building 231-Z for “finishing.” 

Chemical separations involved potentially-high radiation exposures. Of particular note was the 

sampling of process solutions on the canyon decks of T and B Plants. Direct gamma radiation levels 

were high and respirators were required. Service and maintenance of canyon cranes also involved 

potentially-high exposures. 

5.2.4 Plutonium Finishing 

Beginning in January 1945, plutonium nitrate solution from the 200 Area chemical separations 

facilities was transferred to the 231-Z Plutonium Isolation Building (also in the 200 Area). In this 

facility, the plutonium was separated from the nitrate solution by adding hydrogen peroxide. The 

plutonium was then dried and shipped to the Los Alamos site for conversion into metallic plutonium 

for weapons use. Operations in 231-Z were performed in large protective boxes equipped with rubber 

gloves and known as the Rubber Glove Line. The 231-Z Building also housed metallurgical and 

analytical laboratories that supported the finishing process. 

Plutonium finishing facilities were plagued with recurring mechanical problems and process 

difficulties. Radiation-related concerns included direct neutron and gamma exposures, airborne 

activity, and surface contamination control. Use of respirators and periodic operation shutdowns were 

necessary. 

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5.2.5 Research and Development 

Early research and development (R&D) was connected directly or indirectly with plutonium 

production. Simultaneously, due to the lack of knowledge regarding nuclear materials, their reactions, 

and their effects on biological and ecological systems, R&D in a wide variety of topical areas was 

initiated. Topics included radiation detection, human radiation experiments, meteorology and 

atmospherics, applied fish studies, radioactive field and reactor effluent studies, environmental and 

biological monitoring, radiobiology, and inhalation studies. R&D focus shifted with time to areas of 

basic research and product improvement. 

Although R&D involved all areas of the Hanford Site, it was mainly associated with facilities in the 

300 Area. The test reactor in the 305 Building began operation in 1943 and the 3706 Radiochemistry 

Building began operation in 1945. A pilot plant for developing separations processes was started in 

the “cold semi-works” Building 321 in 1945. Another noteworthy early R&D facility was the 100-F 

Area for biological studies. 

5.2.6 Tank Farms and Waste Management 

The Hanford Site mission was to bring facilities on line and operate them through WWII. Early waste 

management was based on limited technical understanding of nuclear physics and engineering. It was 

anticipated that problems in waste management would be addressed as technology developed. There 

are very limited records of waste disposal activities at Hanford during the Manhattan Project period. 

Many of the initial waste management practices were developed by trial and error; modifications were 

made as knowledge increased and undesirable and impractical practices were identified. Plutonium 

production operations produced large quantities of radioactive waste. The largest amounts and the 

most hazardous wastes were those from the separations operations in the 200 Areas. 

The following categories of radioactive waste were generated by Hanford operations: 

•	 Low-level liquid wastes were generally discharged to ponds, trenches, cribs, and injection wells. 

There were numerous such facilities located throughout the site. From these facilities, the liquids 

would percolate into the surrounding soil. 

•	 High-level liquid wastes were collected in large storage tanks, from 6-11 feet below ground. 

These storage tanks were all located in the 200 Areas. Sixty four (64) single-shell tanks were 

constructed during 1944 and 1945, ranging in capacity from 55,000 to 1,000,000 gallons. 

•	 Solid wastes were buried in facilities, ranging from shallow pits to large lined excavations. Most 

burials were at least 18 feet deep. There were multiple solid waste burial sites in the 100, 200, and 

300/600 Areas. Burial distance above groundwater varied from approximately 5 feet in the 100, 

300, and 600 Areas to 55 feet in the 200 Areas. 

•	 Airborne effluents were discharged to the atmosphere through stacks. During initial production 

efforts, air discharges were not treated or filtered. 

Each major functional area included its own waste management facilities and methods. Functional 

areas generated significantly different waste volumes and activities: 

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•	 Fuel fabrication wastes included low-level liquids, solids, and air effluents. These wastes 

contained predominantly uranium. Radiation from uranium associated with fuel fabrication was 

considered relatively minor compared to other site radionuclides and activities. However, some 

wastes from the 300 Area R&D activities contained much higher levels of fission products, such 

as cesium-137 and strontium-90, activated metal components, and transuranics. Liquid low-level 

wastes were collected in a process sewer which emptied into ponds located east of the 300 Area. 

Sludge from the ponds was periodically dredged to recover the uranium. 

•	 Reactor wastes contained fission and activation products, transuranics, and uranium. Cooling 

water from the single-pass systems was discharged to the Columbia River. Low-level liquid 

wastes, including liquids from the 100-F Animal Farm experiments, were placed in trenches or 

cribs from which they entered soil columns. Although radionuclides were primarily short halflife, wastes included some with longer half lives, such as strontium-90, cesium-137, hydrogen-3, 

neptunium-237, plutonium-239, and uranium. There were no high-level liquid wastes from 100 

Area operations. Solid wastes consisted primarily of protective clothing, reactor hardware and 

components, tools, and miscellaneous trash. 

•	 Separations and plutonium finishing wastes in the 200 Areas contained fission products (primarily 

cesium-137 and strontium-90) and uranium. Low-level liquids were released to soil through 

ponds, trenches, French drains, cribs, and injection wells. High-level wastes were piped to 

underground storage tanks. As previously indicated, separations operations produced large 

quantities of liquid waste containing high levels of radioactive materials along with hazardous 

chemicals constituents. Solid wastes, disposed of in 200 Area burial grounds, consisted primarily 

of process hardware, construction debris, protective clothing, and soil contaminated by spills from 

storage tanks. 

•	 Airborne effluents were released through 200-foot high stacks. During early production years, no 

treatment was provided to control airborne releases. The predominant radionuclide released in 

early operations was iodine-131. Other main contaminants included ruthenium-103, ruthenium106, cerium-144, and strontium-90. 

Numerous problems associated with waste management operations resulted in the spread of 

contamination and elevated radiation levels. Exposure rates up to 200 R/h were encountered during 

routine handling of solid waste. Waste fires occurred in solid waste burial sites in all major Areas. 

Containers of waste were ruptured during transport and from the weight of backfill soil. There were 

frequent leaks in underground storage tanks and waste transport lines. Cribs overflowed or otherwise 

malfunctioned, resulting in contamination of soil, groundwater, vegetation, and wildlife. In 1945, the 

300 Area pond dike broke, releasing 14 million gallons of low-level liquid waste into the Columbia 

River. Reactor retention basins leaked, allowing low-level liquid waste to enter underlying soil. 

Prior to installation of filters in 1947, flakes contaminated with iodine-131, ruthenium-103, 

ruthenium-106, cerium-141, strontium-90, and other radionuclides were occasionally discharged from 

the separations stacks and contaminated the areas around the separations plants. Personnel in the 

vicinity of the plants were required to wear respiratory protection. 

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5.2.7 Summary of Key Hanford Site Facilities 

Table 5-2 summarizes the key Hanford Site radiological facilities and operations. 

Table 5-2: Key Hanford Site Facilities and Operations (1943 through August 1946) 

Areas Key Facilities Operations 

100 

105-B, -D, and -F 

Reactor buildings; each contained: graphite core reactor for irradiation of uranium 

fuel elements to produce plutonium; storage pool; handling facilities for irradiated 

fuel. 

103-B, -D, and -F Storage of un-irradiated fuel elements awaiting insertion into the reactor. 

111-B Facility for performing metallurgical tests on reactor materials. 

100-F Animal Farm Area for conducting research on effects of radiation and radioactive materials on 

animals and fish. 

107-B, -D, and -F Retention basins for reactor cooling water. 

200 212-N, -P, and -R Lag storage buildings located in 200 North for storage of irradiated fuel awaiting 

dissolution. 

213-J and -K Magazine storage buildings located in 200 North for storage of plutonium nitrate 

paste from 231-Z. 

221-T and -B 

Chemical separation buildings. T Plant was in 200 West; B Plant in 200 East. Used 

a bismuth phosphate process on irradiated fuel elements to separate plutonium from 

uranium and fission products. 

224-T and B Bulk reduction buildings. Plutonium in solution from 221 Buildings was further 

purified and concentrated. 

221-U 

Chemical separation building located in 200 West. Design similar to T and B 

Plants, but used for training, decontamination, and repair to support other separation 

operations. 

231-Z Finishing building located in 200 West. Converted material from bulk reduction 

facilities to plutonium nitrate paste. 

216-E Waste disposal trench located in 200 East. Used for burial of solid radioactive 

waste. 

241-B, -C, -T, and -U 

Underground storage tanks for high-level liquid waste from separations operations. 

Each group contained 16 tanks. B and C tank farms were in 200 East; T and U 

farms in 200 West. 

222- B, -T, and -U Sample preparation laboratories to support operations in the 221 and 224 Buildings. 

291- B, -T, and -U Exhaust buildings and stacks. Provided exhaust ventilation for 221 and 224 

Buildings. 

2723-W Laundry for work shoe repair and cleaning clothing worn in 100 and 200 Areas. 

Only one facility - in 200 West. 

300 303-A, -B, -C, -D, -E, 

-F, -G, J, and -K 

Used for storage of uranium metal to be fabricated into fuel elements. 

305 Test reactor for development of fuel and reactor materials. 

313 Metal Fabrication building. Uranium slugs were prepared and canned for 

irradiation. 

314 Press building. Extrusion and straightening of uranium rods in preparation for 

cutting into slug lengths and canning. 

3706 Radiochemistry laboratory to support all Hanford Site operations. 

321 Separation building. Also known as “cold semi-works.” Pilot studies to support 

development of separations processes. 

316 Waste disposal trench used for burial of radioactive solid wastes. 

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5.3 Radiological Exposure Sources from Hanford Operations 

During the period of October 1943 through August 1946, there was a potential for exposure radiation 

from a variety of internal and external sources. The primary mission of the Hanford Site was 

plutonium production; consequently, there were potential exposures to that material. In addition, 

other operations related to plutonium production also entailed potential exposures. For example, fuel 

fabrication from natural uranium gave rise to potential direct beta and photon exposures and to 

airborne exposure; reactors used to irradiate fuel elements generated direct beta, photon, and neutron 

radiation fields and the potential for surface and airborne contamination by uranium and a wide 

variety of fission and activation products; separations processes, research and development activities, 

and the collection and disposal of radioactive wastes also resulted in potential direct exposures to 

direct alpha, beta, photon, and neutron radiation fields and the potential for exposures to surface and 

airborne contamination by uranium and a wide variety of fission and activation products. 

5.3.1 Alpha Particle Emissions 

Primary alpha particle-emitting radioactive materials at the Hanford Site were uranium, plutonium, 

and other transuranic materials produced by the irradiation of uranium fuel. Table 5-3 lists the 

alpha-emitting radionuclides and their primary alpha energies. 

Table 5-3: Principal Site Alpha-Emitting Radionuclides 

Radionuclide Energy (MeV) 

Plutonium-238 5.46 (28%), 5.50 (72%) 

Plutonium-239 5.11 (11%), 5.16 (88%) 

Plutonium-240 5.12 (24%), 5.17 (76%) 

Americium-241 5.44 (13%), 5.49 (85%) 

Neptunium-237 4.78 (75%), 4.65 (12%) 

Uranium-234 4.72 (28%), 4.77 (72%) 

Uranium-235 4.37 (18%), 4.40 (57%), 4.58 (8%) 

Uranium-238 4.15 (25%), 4.20 (75%) 

5.3.2 Beta Radiation Fields 

The primary sources of beta exposure were fission and activation products from reactor operations. 

The greatest potential for exposure to beta radiation from these materials was during the separations 

process and subsequent waste handling after the material was separated from the solid fuel and placed 

in a dispersible form. Beta radiation was also present from un-irradiated uranium fuel, but at 

significantly lower levels than encountered after the fuel was irradiated during reactor operations. 

Table 5-4 lists major beta-emitting radionuclides and the maximum beta energies and abundances of 

their primary beta energies. 

Table 5-4: Hanford Site Beta-Emitting Radionuclides 

Radionuclide Maximum Energy (MeV) 

Strontium-90/Yttrium-90 0.546 (100%) / 2.28 (100%) 

Cesium-137 0.512 (95%) 

Iodine-131 0.248 (2.1 %), 0.334 (2.2 %), 0.607 (90%) 

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Table 5-4: Hanford Site Beta-Emitting Radionuclides 

Radionuclide Maximum Energy (MeV) 

Cerium-144 0.318 (77%), 0.185 (20%) 

Ruthenium-106/Rhodium-106 3.54 (79%), 2.41 (10%), 3.03 (8%) 

Ruthenium-103/Rhodium-103 0.226 (91%) 

Protactinium-234m (uranium decay chain) 2.29 (98%) 

Thorium-234 (uranium decay chain) 0.103 (21%), 0.193 (79%) 

Plutonium-241 0.021 (100%) 

5.3.3 Neutron Exposures 

Neutrons were produced by the reactor fission process. Thick biological shields surrounded reactor 

cores to moderate and absorb neutrons. During the separation and finishing processes, plutonium 

alpha particles interacted with low-atomic-number elements (e.g., fluorine and oxygen) in chemical 

reagents, plutonium compounds, and facility structural materials to produce neutrons. The Hanford 

TBD for Occupational External Dose (ORAUT-TKBS-0006-6) provides information regarding 

neutron sources, energy spectra, and neutron-to-photon ratios associated with various site operations. 

5.3.4 Photon Exposures 

Photons associated with plutonium are of low energy and would be shielded by construction materials 

in processing and handling facilities. However, the fission process releases high levels of photon 

radiation, and the fission and activation products resulting from fuel irradiation in reactors decay by 

photon emission. Biological shields around reactor cores reduced the levels of fission photons and 

photons from irradiated fuel within the core. After discharge from the reactor, irradiated fuel elements 

were stored under water and handled with remote tools to limit exposures. Photons from irradiated 

fuel were a concern throughout the latter stages in the plutonium production process, including 

transportation, chemical separation, waste management, and equipment maintenance. R&D activities 

utilized a wide variety of radionuclides with similar photon emissions as those generated in the fuel 

irradiation operations. The Hanford TBD for Occupational External Dose (ORAUT-TKBS-0006-6) 

provides information regarding photon sources and energy spectra associated with various site 

operations 

5.3.5 Incidents and Fires 

Reviewed documents contain general references to problems related to of radiation exposure control. 

Sections 5.2.2 through 5.2.6 briefly describe these problems. However, only a few specific incidents 

or releases were reported in these documents for the time period under evaluation: 

•	 In 1945, the 300 Area pond dike failed, releasing 14 million gallons of low-level liquid waste into 

the Columbia River. 

•	 Prior to installation of filters in 1947, flakes contaminated with iodine-131, ruthenium-103, 

ruthenium-106, cerium-141, strontium-90, and other radionuclides were occasionally discharged 

from the separations stacks and contaminated the areas around the separations plants. Personnel in 

the vicinity of the plants were required to wear respiratory protection. 

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6.0 Summary of Available Monitoring Data for the Proposed Class 

The primary sources of monitoring data for this evaluation include the NIOSH Site Research Data 

Base (SRDB), the NIOSH OCAS Claims Tracking System (NOCTS), the Comprehensive 

Epidemiologic Data Resource (CEDR) database, and the Hanford Radiological Exposure (REX) 

system database. NIOSH investigated the REX database (maintained by the Hanford Site) and the 

CEDR database for available internal and external monitoring data. In addition, the NOCTS database 

was reviewed for claimant exposure data. Copies of many of the Hanford records are contained in the 

SRDB. Reviews of these sources identified personal monitoring data (e.g., film badge exposure 

results, TLD monitoring results, bioassay results) and area monitoring data. 

Radiation protection was a major concern at Hanford from the beginning of operations. Throughout 

most of Hanford’s history, considerable research was conducted toward improving survey 

instruments, effluent clean-up mechanisms, monitoring instrumentation, workplace air-sampling 

practices, and improved understanding of the biokinetics of radionuclide intakes (ORAUT-OTIB0002). The science and practice of monitoring for intakes of plutonium, uranium, and mixed fission 

and activation products were in their infancy in the 1940s. Knowledge and skills associated with 

routine bioassay for plutonium and uranium were rapidly being developed and improved, and the 

scope of monitored workers was expanding. 

6.1 Hanford Internal Monitoring Data 

Based on the data resources listed in Section 6.0 and other source documents, NIOSH has determined 

that internal monitoring data for Hanford employees are not available for the 1943-1946 time period. 

When plutonium production at Hanford commenced, a bioassay program to monitor employees for 

internal dose was still in the early stages of development. From 1943 to 1946, the site operated three 

production reactors, a fuel manufacturing facility with its associated test reactor, and four processing 

plants before a routine bioassay program was in place. 

According to the history compiled by R. H. Wilson in 1987 (PNL-6125), a special studies group was 

formed in 1944. One of the priority tasks for this group was to determine a way to measure plutonium 

in the body. Limits on the amount of plutonium in the body were set as early as 1944, and, after 

experimentation with various methods, routine urine sampling and analysis for plutonium was 

initiated in September 1946. Urinalysis for uranium was piloted in 1946 also and was well established 

by 1948. Urinalysis for fission products started in this time frame as well, although the Wilson 

document indicates that separation from potassium-40 was not always successful prior to 1949 

(ORAUT-TKBS-0006-5, p.8-9). 

The intake radionuclides of concern at Hanford during the DuPont years have been plutonium, 

uranium, fission products, and activation products. 

Although some records of uranium bioassay during the DuPont years are available, the Wilson history 

states that the uranium urinalysis program prior to 1948 was not reliable. The fluorometric method, 

which fused uranium from raw urine with sodium fluoride and measured the fluorescence when the 

compound was exposed to ultraviolet light, was implemented sometime during the first half of 1948 

(PNL-6125; HW-10522). 

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Routine fission product urinalyses started in January 1947, but ferrous hydroxide precipitation was 

used on the supernatant from the plutonium lanthanum fluoride procedure, and the results were erratic 

with occasional breakthrough of K-40. So, data prior to 1948 are considered unreliable (ORAUTTKBS-0006-5, p.27). 

Considerable numbers of thyroid scans (hundreds per month) were being done for workers in the 

separation (canyon) buildings during the 1940s. There was a concern about potential I-131 uptake for 

workers who entered the canyons (e.g., crane operators). No information has been located in the 

records documenting what instruments were used, what MDAs were applicable, or what the actual 

results were. The tolerance level for iodine-131 in air was established in October 1945 as 1x10-7 

μCi/cm3 (Cantril, 1945) based on a permissible equilibrium amount in the thyroid of 2 μCi. Based on 

other statements in the monthly reports, it is reasonable to assume that scans showing thyroid burdens 

over 2 μCi would have been considered significant (ORAUT-TKBS-0006-5, p.7). 

In vivo counting equipment and techniques were not developed until the late 1950s and were not 

routinely used until 1960 (ORAUT-TKBS-0006-5, p.33). 

Details regarding the various analyses used and the associated minimum detectable activities are 

presented in the Hanford TBD for Occupational Internal Dose (ORAU-TKBS-0006-5). 

6.2 Hanford External Monitoring Data 

The following discussion provides a general summary of the Hanford Site external dosimetry 

program, as well as the types, quantity, and quality of data that can be used for external dose 

reconstruction. Details regarding the external dosimetry equipment, methodologies, and techniques in 

use during the time period of the proposed class are described in Manual of Standard Procedures: 

Personnel Meters (Hart, 1946). Administrative practices are generally described in Historical Review 

of Personnel Dosimetry Development and its Use in Radiation Protection Programs at Hanford, 

(PNL-6125). A description of the historical recorded dose values is provided in Historical Hanford 

Radiological Record Description (Fix, 2001). Hanford monitoring practices were essentially the same 

as those used at other major MED facilities, such as University of Chicago and Clinton (Oak Ridge). 

Based on available records, it appears that dosimeters were assigned to all workers who entered 

controlled radiation areas. Beginning with fuel fabrication operations in late 1943, pencil ionization 

chambers (PICs) were used to record doses to beta/gamma radiation. These PICs were prone to 

malfunction and/or accidental loss of charge, which typically results in high results. Therefore, dual 

PICs were issued to each worker to avoid assigning erroneously high radiation levels resulting from 

such performance problems. PICs were read and the readings recorded daily on an individual’s 

dosimetry record card. 

Starting in October 1944, two-element film dosimeters were issued and processed in-house. These 

two-element dosimeters presented difficulties in distinguishing between beta and low-energy photon 

radiations. Use of PICs continued as a contingency for damaged film dosimeters, but the film 

dosimeter was considered the official dose record. The weekly result was manually recorded on the 

individual’s card and compared for compliance with radiation control limits. Early dosimetry records 

are often difficult to read and interpret (Fix, 2001). 

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Annual summaries of external dosimetry records, beginning in 1944, have been entered into the 

Hanford Radiological Exposure (REX) database, with the exception of records for those early DuPont 

workers who transferred with the DuPont organization to other work locations when General Electric 

Company took over as Hanford operating contractor. 

Extremity film dosimeters were provided for monitoring the hands of fuel fabrication workers and for 

monitoring workers in other operations with potential for significant external radiation levels to the 

hands (e.g., personnel responsible for discharging irradiated fuel elements and transferring freshlydischarged fuel). These extremity film dosimeters were also read and recorded weekly. 

Hanford implemented use of PICs with a liner enriched with boron-10 in 1944. These dosimeters did 

not permit distinguishing doses from different neutron energy groups; these PICs were, therefore, 

primarily useful for monitoring the presence of neutrons rather than neutron dose. NTA neutron 

dosimeters were not available at Hanford until 1950. 

Table 6-1 contains annual dose summary statistics for Hanford years 1944 through 1946. 

Table 6-1: Summary Statistics of Monitoring Data for Hanford (1944-1946) 

Year No. of Monitored 

Employees 

Positive Photon 

Dose Results 

Positive Neutron 

Dose Results 

Positive NonPenetrating Dose 

Results 

1944 3495 1499 0 292 

1945 5826 3573 0 1053 

1946 4195 3466 0 1947 

Source: PNL-8909, Tables A.5, A.6, and A.11 

Details regarding the various analyses used and the associated minimum detectable activities are 

presented in the Hanford TBD for Occupational External Dose (ORAUT-TKBS-0006-6) and the 

External Coworker Dosimetry Data for the Hanford Site (ORAUT-OTIB-0030). 

6.3 Hanford Air Sampling Data 

Air monitoring at Hanford was based on gross alpha and gross beta measurements corrected for radon 

progeny. Limited air sampling results are available for this time period from the weekly and monthly 

reports of the Health Instrument Section of the Medical Department. These were brief summaries, 

mostly highlighting problems or indicating that air concentrations were below concern. Often no 

values were given, and locations relative to the workers location are unknown. In addition, air sample 

data from the reactors were almost never listed in these reports (ORAUT-TKBS-0006-5, p. 6). Table 

6-2 summarizes located air sample data for the period: 

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Table 6-2: Hanford Air Sampling Data 

Year Facility Maximum Concentration 

(μCi/cm3

) 

Most Sampler 

Concentrations

 (μCi/cm3

) 

1943 Building 305 Test Reactor 

1944 B Reactor 

D Reactor 

T Plant 

1945 T,U,B Canyon Bldgs 8E-12 Pu <8E-13 Pu 

T,U,B Concentrator Bldgs (224T,U,B) 2E-11 Pu <2E-12 Pu 

D Reactor 

B Reactor 

F Reactor 

231-Z One at 8E-11 Pu, very temporary and area 

immediately placed on mask; most highs were 

about 8E-12 Pu or less. 

<8E-13 Pu 

300 Area Labs 6E-12 Pu <8E-13 Pu 

Metal Fabrication Bldgs. 1E-9 Unat <2E-10 Unat 

1946a T,U,B Canyon Bldgs. 4E-12 Pub 

T,U,B Concentrator Bldgs. 

 D Reactor 

 B Reactor 

 F Reactor 

231-Z 4E-11 Pu 8E-13 Pu 

300 Area Metal Fabrication Bldgs. 2E-9 Unat <1E-10 Unat 

3706 Bldg. 6E-12 Pu, 5E-10 Unat <2E-12 Pu 

200 W Laundry 1E-11 Pu 4E-12 Pu 

Source: Hanford Occupational Dose TBD, ORAUT-TKBS-0006-5 (Table 5.1-1)
 

Notes: 

a

 Based on monthly reports for July and September through December only. b

 Excluding one incident in B Canyon involving only two workers, for which special urine samples were obtained. 

7.0 Feasibility of Dose Reconstruction for the Proposed Class 

The feasibility determination for the proposed class of employees covered by this evaluation report is 

governed by both EEOICPA and 42 C.F.R. § 83.13(c)(1). Under that Act and rule, NIOSH must 

establish whether or not it has access to sufficient information either to, estimate the maximum 

radiation dose for every type of cancer for which radiation doses are reconstructed that could have 

been incurred under plausible circumstances by any member of the class, or to estimate the radiation 

doses to members of the class more precisely than a maximum dose estimate. If NIOSH has access to 

sufficient information for either case, NIOSH would then determine that it was feasible to conduct 

dose reconstructions. 

In determining feasibility, NIOSH begins by evaluating whether current or completed NIOSH dose 

reconstructions demonstrate the feasibility of estimating with sufficient accuracy the potential 

radiation exposures of the class (discussed in Section 9.0 of this report). If the conclusion is one of 

infeasibility, NIOSH systematically evaluates the sufficiency of different types of monitoring data, 

process and source or source term data, which together or individually might assure that NIOSH can 

estimate either the maximum doses that members of the class might have incurred, or more precise 

quantities that reflect the variability of exposures experienced by groups or individual members of the 

class as summarized in Section 7.6. This approach is discussed in OCAS’s SEC Petition Evaluation 

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Internal Procedures which are available at http://www.cdc.gov/niosh/ocas. The next four major 

subsections of this Evaluation Report examine: 

• the sufficiency and reliability of the available data. (Section 7.1) 

• the feasibility of reconstructing internal radiation doses. (Section 7.2) 

• the feasibility of reconstructing external radiation doses. (Section 7.3) 

• the bases for petition SEC-00057-1 as submitted by the petitioner. (Section 7.4) 

7.1 Pedigree of Hanford Data 

This subsection answers questions that need to be asked before a feasibility evaluation is performed. 

The topic of Data Pedigree addresses the background, history, and origin of the data. It requires 

looking at site methodologies that may have changed over time; primary versus secondary data 

sources and whether they match; and whether data is internally consistent. All these issues form the 

bedrock of the researcher’s confidence and later conclusions about the data’s quality, credibility, 

reliability, representativeness, and sufficiency for determining the feasibility of dose reconstruction. 

The feasibility evaluation presupposes that data pedigree issues have been settled. 

Performing internal and external dose reconstructions requires worker monitoring data or source term 

and process information. Worker monitoring data includes data from members of the proposed class 

as well as data from workers outside the proposed class who were performing jobs with higher 

exposure potentials. Using such co-worker monitoring data provides a means for calculating 

claimant-favorable and maximum potential radiation doses for class members who were unmonitored 

or have gaps in their monitoring records. 

7.1.1 Internal Data Review 

NIOSH has found that the internal monitoring data and source term are insufficient for estimating 

most internal radiation doses with sufficient accuracy for members of the proposed class. A notable 

exception is the ability to estimate internal doses associated with uranium fuel fabrication activities 

utilizing available process descriptions and existing dose reconstruction techniques. 

7.1.2 External Data Review 

Hanford policies appear to have been in place for all significant external dosimetry parameters. A 

1990 evaluation of the Hanford program identified no significant administrative practice that would 

jeopardize the integrity of the recorded external dose (PNL-7447). Two reviews of external dose 

records have been conducted. A Study of Detailed Dosimetry Records for a Selected Group of 

Workers Included in the Hanford Mortality Study (PNL-7439), found agreement between original 

paper records and the computerized Hanford Radiological Exposure (REX) Database. A study by the 

University of Pittsburgh, Feasibility Study of the Correlation of Lifetime Health and Mortality 

Experience of AEC and AEC Contractor Employees with Occupational Radiation Exposure 

(NYO-3394-5), concluded that good quality control was exercised over the film badge calibration and 

processing procedures at Hanford over the years covered by the proposed class. 

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7.2 Internal Radiation Doses at Hanford 

The principal source of internal radiation doses to members of the proposed class would have been 

inhalation and ingestion of radiological contamination during the following operations: 

1. Fabrication of uranium metal fuel elements 

2. Irradiation of fuel elements in reactors to produce plutonium-239 

3. Chemical separation of plutonium-239 from irradiated fuel elements 

4. R&D support of production operations and biological and ecological systems 

5. Waste management operations supporting all site radiological activities 

The potential internal sources would have been dependent on the operational area and activities. For 

example: in fuel fabrication areas - natural to very slightly-enriched uranium; in reactor facilities – 

mixed fission and activation products; in separations and finishing facilities, fission/activation product 

(6% plutonium-239 mix). Potential internal sources from R&D, waste management, and other 

support operations would have been dependent on the particular activities. 

7.2.1 Process-Related Internal Doses at Hanford 

As indicated in Section 6.1, there are no bioassay or in-situ monitoring data from the onset of Hanford 

Site operations in 1943 through August 1946 that would allow direct reconstruction of an individual’s 

internal dose. Weekly Health Instrument Section reports for the 100 Areas and the 300 Area provide 

limited air sampling data (HW-7-1635). However, these data are primarily for the fuel fabrication and 

separations facilities and provide practically no monitoring data for reactor and other Site operations. 

The contributions of the Health Instrument Section of the Medical Department to the Hanford 

Engineer Works Monthly Reports during 1945 summarize the weekly air data, but provide no further 

information or detail (HI Reports). Furthermore, NIOSH has not identified documentation describing 

air monitoring devices, sampling techniques, sample measurement and analytical methods, or 

information regarding air monitoring locations and their relationship to potentially-exposed 

individuals. 

As a result of these limitations, NIOSH cannot establish maximum internal exposure scenarios that 

address all of the internal exposure potentials for the proposed class, and therefore, cannot estimate 

internal doses for members of this class with sufficient accuracy. NIOSH does however feel that it 

has sufficient process information to apply existing dose reconstruction (overestimating) techniques to 

bound internal doses associated with the uranium fuel fabrication work. 

7.2.2 Ambient Environmental Internal Radiation Doses at Hanford 

ORAUT-TBKS-0006-4, Hanford Site-Occupational Environmental Dose, describes the principal 

potential sources of dose received by individual while outside operational facilities on the Site. The 

principal potential source during the time period of the proposed class was inhalation of radionuclides, 

discharged from stacks of the T and B separations facilities and the 231-Z finishing plant. Levels 

during the early operations were high, because filtration was not yet available to restrict effluent 

discharges. Another potential source was discharges from the 100-B, -D, and -F reactor facilities. 

Estimated annual intakes of major radionuclides from these sources are provided in this reference and 

are summarized in Table 7-1 below. 

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Table 7-1: Annual Intakes of Particulate Radionuclides 

Radionuclide 1944 1945 1946 

Bq GSD Bq GSD Bq GSD 

I-131 2.88E+02 3.78 1.04E+05 1.94 2.42E+04 1.90 

Zr/Nb-95 1.91E-01 5.33 5.24E+01 2.60 7.29E+01 2.41 

Ru/Rh-106 1.19E-02 2.87 4.09E+00 1.69 7.28E+00 1.63 

Ru/Rh-103 1.83E-01 2.87 3.40E+01 1.68 4.28E+01 1.64 

Sr/Y-90 4.84E-03 2.46 1.45E+00 1.59 2.67E+00 1.56 

Ce/Pr-144 1.45E-01 2.46 3.79E+01 1.59 6.64E+01 1.56 

Cs/Ba-137 4.18E-03 2.46 1.28E+00 1.59 2.35E+00 1.56 

Pu-239 9.75E-06 12.00 6.84E-03 7.04 1.47E-02 6.43 

Source: ORAUT-TKBS-0006-4. 

7.2.3 Internal Dose Reconstruction 

An approach for estimating internal exposures for unmonitored time periods (i.e., periods for which 

bioassay data are not available) is described in Section 6.0 of ORAUT-OTIB-0039, Internal 

Dosimetry Coworker Data for the Hanford Site. This approach is based on extrapolation back to the 

Hanford DuPont years from measured exposures during periods of comparable operations and 

production levels—conditions present at Hanford during the time period immediately following 

September 1, 1946. This approach also assumes an active and effective radiological protection 

program that provides quality air monitoring data and demonstrates compliance with established air 

concentration tolerance levels during an unmonitored time period. The intake rate during the 

monitored time period is estimated from bioassay data. This intake rate is then multiplied by a factor 

representing the ratio of the air concentration tolerance level during the unmonitored period to the 

tolerance level during the monitored period to provide an estimate of the intake rate for the 

unmonitored period. 

Further adjustments to this intake rate estimate may be made to account for other differences between 

the monitored and unmonitored periods, such as changes in relative radionuclide ratios due to 

variations in cooling times and radiological ingrowth, and modifications to production levels. Use of 

this approach may be considered appropriate, provided the issue of air sampling data quality for the 

unmonitored time period can be favorably resolved. Another option particularly applicable to 

exposures associated with Hanford uranium fuel fabrication is to utilize process and source knowledge 

in conjunction with data available from other sites performing similar work. With this information, 

NIOSH can employ existing dose reconstruction techniques to calculate conservative (bounding) 

plausible exposures. 

7.2.4 Internal Dose Reconstruction Feasibility Conclusion 

Based on the absence of bioassay data for the period prior to September 1, 1946, the limited quantity 

of air monitoring data available for review (particularly for reactor and separations operations), and 

the lack of specificity regarding the location of air monitoring data relative to potential worker intake, 

NIOSH has concluded that internal dose reconstruction is not feasible, with the exception of those 

associated with uranium fuel fabrication. 

. 

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7.3 External Radiation Doses at Hanford 

The principal sources of external radiation to the proposed class are those associated with nuclear fuel 

fabrication, nuclear reactor operations, and the radiochemical separation/refinement/finishing/storage 

of plutonium. The processes that generated the principal sources of external radiation dose are 

described in Section 5.0 of this document. 

7.3.1 Process-Related External Radiation Doses at Hanford 

The following subsections summarize the extent and limitations of information available for 

reconstructing the process-related external doses of members of the proposed class. 

7.3.1.1 Radiation Exposure Environment 

The external dose received by workers at Hanford during the DuPont years was a function of the 

physical location of the workers on the site, the process taking place, the type and quantities of 

material present, and the time spent in each location. The radiation contributing to external dose was 

primarily beta and photon (including X-rays) and neutron. 

Beta and Photon Characterization 

The beta and photon radiations are well characterized in TBD ORAUT-TKBS-0006-6, Appendix A, 

Table A.2. A summary of the Table A.2 is provided in Table 7-2: 

Table 7-2: Default Beta and Photon Energies/Percentages for Hanford DuPont Operations 

Area Starting Date Radiation 

Type <30 keV 30-250 keV >250 keV 

105-B, -D, and -F 

Reactors September 1944 Photon a 0% 25% 75% 

Plutonium 

Separation and 

Extraction, T, B 

Plants 

December 1944 Photon a 0% 25% 75% 

Plutonium 

Concentration and 

Storage, Z-Plant 

January 1945 Photon 25 75% 0% 

Waste Handling January 1945 Photon a 0% 50% 50% 

Source: ORAUT-TKBS-0006-6, Appendix A, Table A.2 

Notes: 

a

 Beta energies in these areas are 100% >15keV. 

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Neutron Field Characterization 

During the DuPont years, Hanford work areas with the potential for neutron exposure included the 

200 Area plutonium separation and concentration facilities, the 305 Test Reactor, and the 100 Area 

production reactors 105-B, -D, and -F. 

At the 200 Area plutonium facilities, neutron radiation was generated from plutonium by either 

spontaneous fission, or importantly, by alpha particle interaction with light elements such as oxygen, 

fluorine, and beryllium. These interactions are commonly referred to as alpha-n reactions. 

At the 100 Area nuclear reactor facilities and the 305 Test Reactor, neutrons were generated by fission 

of uranium and plutonium in the reactor core. Neutron exposures for workers in the reactors were 

accompanied by photon radiation that was readily measured with Hanford portable instruments, 

pocket ionization chambers (PICs), and personnel film dosimeters. These facilities generally had 

extensive shielding to reduce worker neutron and photon radiation exposure in most work areas. 

Neutron radiation was significant only while a reactor was in operation and only in those areas of a 

reactor that were typically closed to general worker access. 

No neutron spectra measurements have been found for the DuPont years at Hanford. 

7.3.1.2 History of Whole Body External Monitoring 

Radiation dosimetry practices were initially based on experience gained during several decades of 

radium and X-ray medical diagnostic and therapy applications. These methods were generally well 

advanced at the start of the Manhattan Engineer District (MED). Hanford had an extensive radiation 

safety monitoring program to measure exposure in the workplace using portable radiation instruments, 

contamination surveys, zone controls, and personnel dosimeters. Doses from the dosimeters were 

recorded at the time of measurement and routinely reviewed by Hanford operations and radiation 

safety staff for compliance with radiation control limits (ORAUT-TKBS-0006-6). 

External dose has been measured and recorded for Hanford personnel since the beginning of 

operations in 1944. During January 1944, before the Hanford film dosimetry system was operational, 

PICs were used for a few months to provide the dose of record (PNL-6125). PICs were issued to 

employees in duplicate (i.e., two to each worker) and exposures were recorded daily. PICs typically 

over-estimated the exposure from routine handling and environmental effects (HW-48751). Because 

of this “false-positive” dose from routine handling and environmental effects, the lower of the two 

daily readings was used to calculate the dose for comparison with then-current daily dose limits. 

Following use as the earliest dosimeters, PICs have been used throughout the history of Hanford 

operations to provide administrative control of worker dose until the personnel dosimeter was 

processed and the dose calculated. It has been routine practice since at least the early 1950s to 

compare the doses measured with PICs and dosimeters and, for significant differences, to document 

the reason(s) for the discrepancy (ORAUT-TKBS-0006-6). 

The Two-Element Film Dosimeter was used from October 1944 to March 1957. This design was used 

at the Clinton Laboratory (now ORNL) and later by other MED/AEC/DOE laboratories. It was based 

on the dosimeter design developed at the Metallurgical Laboratory in Chicago, Illinois, by Pardue, 

Goldstein, and Wollan. The minimum detectable dose based on laboratory irradiations was 0.3 mSv 

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(30 millirem), and the routine dosimeter exchange period was weekly. During the years 1944-1947, 

Hanford assigned skin dose based on the dosimeter open window reading plus the silver-filtered 

dosimeter reading (ORAUT-TKBS-0006-6). 

Routine Hanford practices appear to have required assigning dosimeters to all workers who entered a 

controlled radiation area. All dosimeters were processed and the measured results were recorded and 

used to estimate dose. There appears to be no use of recorded notional doses, although there are 

issues of “missed” recorded dose for low-dosed dosimeters as well as recorded doses for individual 

dosimeters at levels less than the statistical Minimum Detection Level (MDL) (ORAUT-TKBS-0006­

6). 

In 1944, Hanford implemented its individual worker neutron dosimetry methods using PICs (see 

Section 7.3.1.4). 

7.3.1.3 History of Extremity Monitoring 

Indications of an extremity dosimetry program exist as early as 1945 with finger-ring dosimeters 

being referred to in weekly Health Instrument Section reports (HW-7-1635). Records indicate that in 

1945, 109 workers were monitored for extremity dose with a total of 349 mSv dose being recorded. 

In 1946, 285 workers were monitored for extremity dose with a total of 1754 mSv dose being 

recorded (PNL-6125, Table A.12). 

The first dosimeter rings measured only beta. Later rings contained a silver shield to detect the 

gamma component, but these could be unsuitable for low-energy photons. Finger-ring dosimeters 

could be bulky and sometimes could not be used in tight areas. In such cases, a pliable film packet 

was used (HW-7-4211). 

7.3.1.4 History of Neutron Monitoring 

In 1944, Hanford implemented its individual worker neutron dosimetry methods using PICs. 

Enriched B-10 liners were used in the PICs to detect slow neutron exposure (PNL-6125). This method 

is generally acceptable to detect the presence of slow neutrons but not for dose measurement 

(ORAUT-TKBS-0006-6). Some attempts were made to measure fast neutrons using a fine-grain film 

to record tracks from recoil protons, but these attempts were unsuccessful (PNL-7447). There is no 

recorded neutron dose for any Hanford worker prior to 1950. In 1950, the NTA emulsion dosimeter 

capability was implemented (ORAUT-TKBS-0006-6). In addition, as reported in the Health and 

Instrument Section weekly and monthly reports, neutron surveys were performed with portable 

neutron survey instrumentation for the purpose of establishing safe workplace radiation levels, so as to 

limit neutron exposures to workers (HI Reports, HW-7-1635). 

7.3.1.5 Dosimetry Records 

Records of radiation doses to individual workers from personnel dosimeters worn by the worker and 

co-workers are available for Hanford operations beginning in 1944 (PNL-8909). As detailed in 

Section 6.2, data and documents covering external dosimetry, and related records covering the DuPont 

operational period, are readily available. An exception could possibly be DuPont corporate 

employees who left the Hanford Engineer Works when DuPont ceased site operation. Reports from 

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interviewees and documents provided by the petitioner confirm that DuPont took the dosimetry 

records with them when they left the site. Workers who stayed on at Hanford retained their exposure 

records from their DuPont years. In addition, the DuPont records could be available in some form in 

the DOE record system at Hanford since these records were used to support the AEC’s Health and 

Mortality Study performed by the University of Pittsburgh during the 1960s and 1970s (Kirklin; 

ORNL 67-3-10). The search for the DuPont records continues as this report is being written. 

7.3.1.6 Application of Co-Worker Data for External Dose Reconstruction 

For unmonitored workers, co-worker doses from photon radiation for Hanford are presented in 

ORAUT-OTIB-0030. Co-worker data may be used for cases not having complete monitoring data 

and may fall into one of several categories including: 

•	 The worker was unmonitored and, even by today’s standards, did not need to be monitored (e.g., a 

non-radiological worker). 

•	 The worker was unmonitored, but by today’s standards would have been monitored. 

•	 The worker may have been monitored but the data are not available to the dose reconstructor. 

•	 The worker may have partial information, but the available information is insufficient to permit a 

dose reconstruction. 

The Hanford Co-worker study was developed using dosimetry data for monitored Hanford workers 

from the CEDR databases maintained by the DOE. The CEDR data evaluated represented primarily 

annual penetrating and non-penetrating dosimetry data provided by the Hanford site, which 

correspond to the shielded and “open-window minus shielded” dosimetry readings, respectively, and 

exclude neutron doses (ORAUT-OTIB-0030). Neutron doses are assigned based on a neutron-photon 

ratio as described later in Section 7.3.4.2 of this report. 

A claimant-favorable approach was adopted in the development of co-worker dose summaries, and 

this approach should account for any underestimate of doses to Hanford radiological workers based on 

the considerations described above (ORAUT-OTIB-0030). 

7.3.2 Ambient Environmental External Radiation Doses at Hanford 

The TBD, Hanford Site Occupational Environmental Dose, ORAUT-TKBS-0006-4, and 

Occupational Onsite Ambient Dose Reconstruction for DOE Sites, ORAUT-PROC-0060, provide the 

rationale, historical background, and data for the reconstruction of occupational environmental doses 

for unmonitored personnel at the Hanford Site. The occupational environmental dose is the dose 

received by individuals while outside operational facilities such as process buildings, chemical 

separations plants, reactors, or other structures. External dose from radioactive materials outside the 

body may be determined from immersion in a cloud of inert gases; deposition of particles on the skin; 

or adjacent operational facilities. 

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7.3.2.1 Ambient Radiation 

Quarterly environmental monitoring reports published from 1945 to 1955 present gamma exposure 

levels at various locations throughout the Hanford site. The measured natural background radiation 

levels from 1946-1948 were 0.3 to 0.5 mrad per day. This natural background was not subtracted 

from the ambient readings. Table 4.8 of ORAUT-TKBS-0006-4 lists the external gamma 

measurements at Hanford from 1944 through 2001, including fallout and background. The values are 

averages in millirem per year for exposures of 2,000 hour/year and can be used to reconstruction dose 

from environmental radiation sources. 

7.3.2.2 Releases of Noble Gases 

Xenon-133 was released from the production reactors and its dose contribution can be estimated by 

comparing it with the iodine-131 release rate and dose conversion factors. At its peak in 1945, when 

Hanford used shorter fuel-element cooling times, the xenon-133 release rate was 42,000 Ci/mo. The 

I-131 release during the peak time was 89,000 Ci/mo. When comparing the dose conversion factors 

and release rates of iodine-131 and xenon-133, the iodine contribution to the dose was more than 

10,000 times larger than that of xenon. Therefore, iodine is listed as a major contributor and Xe-133 

is not (ORAUT-TKBS-0006-4). 

Argon-41 was released from the Hanford reactors as a neutron activation product of stable argon in air 

and not from the chemical separations facilities. Effluent concentrations were measured for only brief 

periods over the years, and the reactors did not operate continuously. Table 4A-11 in ORAUT-TKBS0006-4 provides submersion gamma dose and skin dose values that can be used to reconstruct dose. 

7.3.2.3 Skin Deposition of Airborne Particulate Emissions 

Starting in 1947, surveys of the ground in the T and B Plant areas revealed contamination in the form 

of discrete particles. The most likely source of these of particles was iron-oxide particulates coated 

with radioactive material from corroding ductwork in the T and B Plant ventilation systems. Analysis 

of the particles indicated that the radionuclides were deposited on the blowers and other iron surfaces 

and were released into the ventilation air stream as the iron parts corroded. Even though the particles 

were not discovered until 1947, there is no evidence that these releases were not on-going from the 

start of operations. These particles were emitted through April 1948 when sand filters were installed 

to stop the releases. The greatest activity measured on a T or B Plant particle was 3.2 μCi with the 

average being 1.1 μCi. ORAUT-TKBS-0006-4, Section 4.3.3, provides a method to estimate dose 

based on a conservative particle activity, the probability that a particle could land on a worker’s skin, 

mean residence times, and dose coefficients for different radionuclides on the particles (ORAUTTKBS-0006-4). 

7.3.3 Hanford Occupational X-Ray Examinations 

Pre-employment, termination, and periodic medical examinations were given to Hanford workers 

from the very beginning of the site. Cantril gives a count of 15 exams being given in December 1943, 

and states that the periodic exam program began in January 1944 (MDDC-602). These examinations 

included a chest X-ray. 

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In the site’s early years, periodic X-ray examinations were relatively frequent. Groups of workers 

identified as being at-risk received medical exams, including X-rays, at more frequent intervals than 

other workers. For work with radiation hazards, interval exams in January 1944 were as close to 

every four weeks as possible. By July 1945, the exam intervals were lengthened from every four to 

every seven or eight weeks. Other employees not working with radiation or other special hazards 

were examined every three to six months. The frequency of medical radiographs was reduced to 

annually until 1959, and thereafter, on a schedule dependent on age but no more frequent than 

annually. 

Review of the available documentation on the occupational medical program at Hanford from 1943 to 

the present revealed that only three diagnostic medical radiographic procedures were administered in 

connection with pre-employment or regular post-employment medical examinations: 

1. Posterior-anterior (PA) 14” by 17” chest film 

2. Lateral (LAT) 14” by 17” chest film 

3. Photofluorographic 4” by 5” chest film 

The 14” by 17” PA chest radiography was the most widely used diagnostic procedure. In some cases, 

stereo views were taken; these required two 14” by 17” films. 

Beginning in March 1945, when Hanford received fluoroscopic equipment, photofluorographic chest 

films were taken. This method resulted in much greater worker doses than a standard radiographic 

procedure. Photofluorography used a smaller film (typically 4” by 5”), a smaller source-to-skin 

distance, and typically resulted in a several-fold greater radiation exposure. Exposure was regulated 

by photometers, which used exposure to the film to determine the time of exposure (MDDC-602; 

ORAUT-TKBS-0006-3). 

7.3.4 External Dose Reconstruction 

Through April 14, 2007, 378 EEOICPA claims from the Hanford workers—for the period of January 

1, 1942 through August 31, 1946— had been submitted to NIOSH. Of those 378 claims, dose 

reconstructions have been completed for 328 claims. These claims cover the entire range of operation 

at Hanford and include claims with external monitoring data. 

There is an established protocol for assessing external exposure when performing dose reconstructions 

(these protocol steps are discussed in the following subsections): 

• Photon and Electron Dose 

• Neutron Dose 

• Unmonitored Individuals Working in Production Areas 

• Medical X-ray 

7.3.4.1 Photon and Electron Dose 

External dose has been measured and recorded for Hanford personnel since the beginning of site 

operations. As previously shown in Table 4-1, the majority of completed dose reconstructions have 

had external dose records provided by DOE. Hanford worker-recorded dose measurements are 

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considered reasonably accurate from 1944 through the present with one exception: the low-energy 

photon dose component measured in the plutonium facilities with the original two-element film 

dosimeter used prior to 1958 may be too low. Stated Hanford practice, for plutonium facilities only, 

was to add to the penetrating dose 20% of the measured non-penetrating dose. However, it has not 

been possible so far to clearly confirm that this practice was done for all years. Therefore, if the early 

photon dose is significant to the dose reconstruction, the penetrating dose may be adjusted by using 

20% of the non-penetrating or shallow recorded dose to ensure a claimant-favorable assigned photon 

dose (ORAUT-TKBS-0006-6). 

Missed dose, which occurs when the dose of record is zero because the dosimeter response was less 

than the MDL, or there is no dose of record for an assigned badge for a monitoring period, is 

accounted for by assigning a missed photon dose based on the MDL/2 method and the number of 

dosimeter exchange periods for the dosimetry system (ORAUT-TKBS-0006-6). 

Hanford began using extremity dosimetry as early as 1945. A standard monitoring practice in 

operational health physics is to establish a factor between whole-body and extremity exposures to 

determine when extremity dosimeters should be assigned. Conservatively, it would not be necessary 

to monitor the extremity dose unless it was greater than three times the whole-body dose. To assign 

extremity dose for workers who have extremity cancer but no extremity dose data, the measured 

whole-body dose should be increased by a factor of three as a claimant-favorable assumption 

(ORAUT-TKBS-0006-6). 

An adjustment for glovebox workers is used to adjust the measured photon dose for Hanford workers 

in plutonium facilities, based on the guidance in Best Estimate External Dose Reconstruction for 

Glovebox Workers (OCAS-TIB-0010). 

To account for the uncertainty in beta/photon dosimeter measurements, a standard error of +30% is 

recommended for use in reconstructing dose. This is based on the estimated standard error of ±30% in 

recorded film badge doses from photons of any energy (ORAUT-TKBS-0006-6). 

Based on the information available to NIOSH, the external photon and electron dose for the class 

under evaluation can be reconstructed with sufficient accuracy. 

7.3.4.2 Neutron Dose 

Neutron dose was monitored during this period using PICs containing enriched B-10 liners to detect 

slow neutron exposure. As stated in Section 7.3.1.4, this method is generally acceptable for detecting 

the presence of slow neutrons but not for dose measurement. Therefore, all neutron dose should be 

treated as missed dose because no neutron dose was recorded before the site started using neutron 

NTA film in 1950. 

ORAUT-TKBS-0006-6 provides neutron-to-photon ratios for assigning neutron dose to employees. 

These ratios are based on work location and measured penetrating photon dose. A neutron dose 

should be calculated for all Hanford facilities with any potential for neutron dose using the specified 

ratio and ICRP energy correction factor (ICRP 60). The photon dose should be adjusted for any 

missed dose before applying the neutron-to-photon ratio to estimate neutron dose. 

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7.3.4.3 Unmonitored Individuals Working in Production Areas 

Although all significantly-exposed Hanford workers should have been monitored with a recorded 

dose, unmonitored Hanford workers can be assigned unmeasured photon dose by using the Hanford 

co-worker doses presented in ORAUT-OTIB-0030, External Coworker Dosimetry Data for the 

Hanford Site. 

Based on the information available to NIOSH, the dose to unmonitored workers in the class under 

evaluation can be reconstructed with sufficient accuracy. 

7.3.4.4 Medical X-ray 

Medical X-rays were performed on Hanford workers from the very beginning as part of their 

pre-employment, termination, and periodic medical examinations. Records of X-rays performed on a 

worker are typically included in the dose records provided by DOE. When records are not available, 

Table 3-3 of ORAUT-TKBS-0006-3, Hanford Site Occupational Medical Dose, provides a guideline 

to determine the number of X-rays. To summarize this table: Up to July 1, 1945, all employees are 

assumed to have had an entrance, exit, and every 3-6 months a 14”x17” PA chest X-ray. Radiation or 

special hazard workers are assumed to have had an X-ray every 4 weeks. After July 1, 1945, the 

radiation and special hazard workers’ periodic interval was increased to 4-8 weeks (ORAUT-TKBS0006-3). Organ doses are provided in ORAUT-TKBS-0006-3, Table 3-5, and are based on 1940s 

X-ray practices and dose factors given in ICRP 34 (ICRP 34; ORAUT-TKBS-0006-3; ORAUTPROC-0061). 

Beginning in March 1945, fluoroscopic equipment was received at Hanford and photofluorography 

chest films were taken at the site. These exams typically have a higher exposure than the 14”x17” PA 

chest X-rays. If uncertain as to the type of X-ray a worker received, the higher exposures due to 

photofluorography can be assumed. Organ dose estimations are provided in Section 3.3.3 of ORAUTTKBS-0006-3. 

ORAUT-TKBS-0006-3 provides a combined statistical uncertainty factor of +30% that can be 

assumed based on uncertainties such as measurement error, time of exposure, distance, and variations 

of tube current. 

Based on the information available to NIOSH, the medical X-ray dose for the class under evaluation 

can be reconstructed with sufficient accuracy. 

7.3.5 External Dose Reconstruction Feasibility Conclusion 

Recorded external dosimetry data are extensive and sufficient for external dose reconstruction. 

NIOSH has established that it has access to sufficient information to either: (1) estimate the maximum 

external radiation dose for every type of cancer for which radiation doses are reconstructed that could 

have been incurred under plausible circumstances by any member of the class; or (2) estimate the 

external radiation doses to members of the class more precisely than a maximum dose estimate. 

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7.4 Evaluation of Petition Basis for SEC-00057-1 

The following subsections evaluate the assertions made on behalf of petition SEC-00057-1 for 

Hanford. 

7.4.1 Evaluation of Major Topics Detailed in Petition SEC-00057-1 

The following are the major topics applicable to the DuPont Hanford years that were detailed in the 

petitions that were merged to form SEC-00057-1. Italicized statements are from the petition; the 

comments that follow are from NIOSH. 

7.4.1.1 Missing Hanford DuPont Area Dosimetry Records 

SEC-00057-1: There are no individual Hanford DuPont worker records in existence because they 

have all been destroyed. 

A review of claims in NOCTS show that records for DuPont-era workers who stayed on at Hanford 

after DuPont left were retained in the Hanford dosimetry files. This is consistent with responses from 

former Health Instrument Section radiation protection personnel interviews. DuPont did remove and 

retain the records for workers who left with DuPont and who had no further employment at Hanford. 

NIOSH reviewed claims in NOCTS for workers who left with DuPont. Some workers were employed 

at the Savannah River Site (SRS) when DuPont was the operator there and their records were 

transferred to SRS. Other workers who left with DuPont appeared to have job descriptions that were 

administrative or managerial in nature; they were unlikely to have been exposed to radiation or 

radioactive material and unlikely to have been monitored. DuPont Hanford exposure data were used 

in the AEC Health and Mortality Study and may be still available if a search is performed on those 

records (Kirklin; Fix, 2007). 

7.4.1.2 Method Used to Estimate Releases Not Claimant Favorable 

SEC-00057-1: The computer program RATCHET has a tendency to underestimate. RATCHET is 

unsuitable to model Hanford emissions. 

The bulk of Hanford releases are episodic in that they resulted from batch processes and they are 

well-modeled using annual averages. To arrive at values for respirable particles, the transport and 

dispersion of the gases, mists, fumes, and small particles was estimated using the RATCHET 

computer code. RATCHET was developed to account for the episodic nature of the iodine (and other 

radionuclide) releases from the Hanford reprocessing plants in response to intense public interest and 

the inability to state a priori that longer-term averaging was adequate. However, subsequent analyses 

have shown that, when the additional uncertainty is appropriately accounted for, averaging over 

periods of months to years provides results that compare very favorably with the values generated 

using hourly release data. Radionuclides other than I-131 were released concurrently with the iodine. 

I-131 concentrations in the atmosphere calculated using the RATCHET model are, in fact, very close 

to those actually measured near Hanford. The other released radionuclides would likewise be 

adequately represented since they were released at essentially the same time as the iodine. (ORAUSC&A, 2007 [draft]) 

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7.4.1.3 Under-recording of Neutron Dose 

SEC-00057-1: Neutron dose was under-recorded for plutonium workers during the period of 1950-

1971 when the Hanford Nuclear Track Emulsion, Type A, (NTA) film was used. 

Although the petitioner is commenting on a time period subsequent to the class under evaluation, the 

concern is relevant because the method for monitoring workers during the DuPont era also 

under-recorded neutron dose. 

To assign neutron dose, a neutron-to-photon dose ratio is applied for each year of employment with a 

potential for neutron exposure. 

Even though there are several sources of photon exposure that do not include an associated neutron 

dose (i.e., reactor maintenance while the reactor is not operating, reactor fuel fabrication, chemical 

processing), applying a neutron-to-photon dose ratio results in assigned neutron dose for these 

“photon only” exposures as well. Overall, the NIOSH expectation is that the reconstructed neutron 

dose will be over-estimated. 

7.6 Summary of Feasibility Findings for Petition SEC-00057-1 

This report evaluates the feasibility for completing dose reconstructions for employees at the Hanford 

Site from October 1, 1943 through August 31, 1946. NIOSH found that the available monitoring 

records, process descriptions, and source term data available are not sufficient to complete dose 

reconstructions for the proposed class of employees. 

Table 7-3 summarizes the results of the feasibility findings at Hanford for each exposure source 

during the time period October 31, 1943 through August 31, 1946. 

Table 7-3: Summary of Feasibility Findings for SEC-00057-1 

(October 1, 1943 through August 31, 1946) 

Source of Exposure Reconstruction Feasible Reconstruction Not Feasible 

Internal 

 - U X 

 - Pu X 

 - Fission Products X 

 - Ambient Environmental1

 X 

External 

 - Gamma X 

 - Beta X 

 - Neutron X 

 - Ambient Environmental2

 X 

 - Occupational Medical x-ray X 

Notes: 

1	 Internal ambient environmental dose reconstruction is considered feasible starting in 1944 per ORAUTTKBS-0006-4 2	 External ambient environmental dose reconstruction is considered feasible starting in 1944 per ORAUTTKBS-0006-4 and ORAUT-PROC-0060 

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As of April 20, 2007, a total of 378 claims have been submitted to NIOSH for individuals who 

worked at Hanford for the period of January 1, 1942 through August 31, 1946. Dose reconstructions 

have been completed for 328 individuals (~87%). 

8.0 Evaluation of Health Endangerment for Petition SEC-00057-1 

The health endangerment determination for the class of employees covered by this evaluation report is 

governed by both EEOICPA and 42 C.F.R. § 83.13(c)(3). Under these requirements, if it is not 

feasible to estimate with sufficient accuracy radiation doses for members of the class, NIOSH must 

also determine that there is a reasonable likelihood that such radiation doses may have endangered the 

health of members of the class. Section 83.13 requires NIOSH to assume that any duration of 

unprotected exposure may have endangered the health of members of a class when it has been 

established that the class may have been exposed to radiation during a discrete incident likely to have 

involved levels of exposure similarly high to those occurring during nuclear criticality incidents. If 

the occurrence of such an exceptionally high-level exposure has not been established, then NIOSH is 

required to specify that health was endangered for those workers who were employed for a number of 

work days aggregating at least 250 work days within the parameters established for the class or in 

combination with work days within the parameters established for one or more other classes of 

employees in the SEC. 

Although NIOSH has determined that, based on available data, estimating radiation dose for external 

radiation is feasible, the lack of routine bioassay for internal exposure as well as limited air sampling 

data make the estimation of internal doses—not associated with uranium fuel fabrication—unfeasible. 

Our evaluation determined that, except for doses from uranium, it is not feasible to estimate internal 

radiation dose for members of the proposed class with sufficient accuracy based on the sum of 

information available from available resources. A modification of the class definition regarding 

health endangerment and minimum required employment periods, therefore, is required. 

9.0 NIOSH-Proposed Class for Petition SEC-00057-1 

This evaluation defines a single class of employees for which NIOSH cannot estimate radiation doses 

with sufficient accuracy. This class includes: All employees of the DOE or DOE contractors or 

subcontractors who were monitored, or should have been monitored, for internal radiological 

exposures while working at the Hanford Engineer Works in: the 300 Area fuel fabrication facilities 

from October 1, 1943 through August 31, 1946; the 200 Area plutonium separation facilities from 

November 1, 1944 through August 31, 1946; or the 100 B, D, and F reactor areas from September 1, 

1944 through August 31, 1946; and who were employed for at least 250 aggregated work days either 

solely under their employment or in combination with work days within the parameters established for 

other SEC classes (excluding aggregate work day requirements). The class was modified from the 

petitioner-submitted class to coincide with the time periods when radioactive materials were used or 

created during DuPont-operated production in the specified areas. 

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NIOSH has carefully reviewed all material sent in by the petitioner, including the specific assertions 

stated in the petition, and has responded to them herein (see Section 7.4). NIOSH has also reviewed 

available technical resources and many other references, including the Site Research Data Base 

(SRDB), for information relevant to SEC-00057-1. In addition, NIOSH reviewed its NOCTS dose 

reconstruction database to identify EEOICPA-related dose reconstructions that might provide 

information relevant to the petition evaluation. 

These actions are based on existing, approved NIOSH processes used in dose reconstruction for 

claims under EEOICPA. NIOSH’s guiding principle in conducting these dose reconstructions is to 

ensure that the assumptions used are fair, consistent, and well-grounded in the best available science. 

Simultaneously, uncertainties in the science and data must be handled to the advantage, rather than to 

the detriment, of the petitioners. When adequate personal dose monitoring information is not 

available, or is very limited, NIOSH may use the highest reasonably possible radiation dose, based on 

reliable science, documented experience, and relevant data to determine the feasibility of 

reconstructing the dose of an SEC petition class. NIOSH contends that it has complied with these 

standards of performance in determining that it would not be feasible to reconstruct the dose for the 

class proposed in this petition. 

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10.0 References 

42 C.F.R. 81, Guidelines for Determining the Probability of Causation Under the Energy Employees 

Occupational Illness Compensation Program Act of 2000; Final Rule, Federal Register/Vol. 67, No. 

85/Thursday, p 22,296; May 2, 2002; SRDB Ref ID: 19391 

42 C.F.R. 82, Methods for Radiation Dose Reconstruction Under the Energy Employees 

Occupational Illness Compensation Program Act of 2000; Final Rule; May 2, 2002; SRDB Ref ID: 

19392 

42 C.F.R. 83, Procedures for Designating Classes of Employees as Members of the Special Exposure 

Cohort Under the Energy Employees Occupational Illness Compensation Program Act of 2000; Final 

Rule; May 28, 2004; SRDB Ref ID: 22001 

42 U.S.C. §§ 7384-7385 [EEOICPA], Energy Employees Occupational Illness Compensation 

Program Act of 2000, as amended 

DOE/RL-97-1047, History of the Plutonium Production Facilities at the Hanford Site Historic 

District 1943 – 1990, U.S. Department of Energy; June, 2002; SRDB Ref ID: 27666 

HI Reports, Contributions of the Health Instrument Section of the Medical Department to the Hanford 

Engineer Works Monthly Reports; Hanford Engineer Works; Mar-Oct and December, 1945; SRDB 

Ref IDs: 5054, 5055, 5057, 5060, 5072, 5085, 5087, 5090, 5098 

HW-7-1635, Weekly Health Instruments Section Reports on the 100 Areas and the 300 Area (05-05­

45 through 12-31-45); H. M. Parker; C. C. Gamertsfelder; May 11, 1945; SRDB Ref ID: 31345 

HW-7-4211, Review of Personnel Monitoring at Hanford Engineer Works, No date readable, SRDB 

Ref ID: 5225 

HW-10522, Bioassay at Hanford, J. W. Healy; Hanford Works; Richland, WA; July 20, 1948; SRDB 

Ref ID: 4909 

HW-48751, Weekly Processing of Pocket Ionization Chambers, E. C.Watson, Radiation Protection 

Operation; Hanford Laboratores Operation; Richland, Washington; April 15, 1957; SRDB Ref ID: 

15402 

ICRP 34, Protection of the Patient in Diagnostic Radiology; ICRP Publication 34: Annals of the 

ICRP, Vol. 9/2; Elsevier Publishing; January, 1983; http://www.elsevier.com 

ICRP 60, Recommendations of the International Commission of Radiological Protection, ICRP 

Publication 60, Annals of the ICRP, Vol. 21; Pergamon Press; Oxford, England; SRDB Ref ID: 11517 

MDDC-602, Industrial Medical Programs: Hanford Engineer Works, Simeon T. Cantril, M.D.; 

Technical Information Division; Oak Ridge Directed Operations; Oak Ridge, Tennessee; November 

15, 1946; SRDB Ref ID: 26814 

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NYO-3394-5, Feasibility Study of the Correlation of Lifetime Health and Mortality Experience of 

AEC and AEC Contractor Employees with Occupational Radiation Exposure; Thomas F. Mancuso; 

Barkev S. Sanders; Allen Brodsky; University of Pittsburgh; May 1965 – May 1966; SRDB Ref ID: 

OCAS-PR-004, Internal Procedures for the Evaluation of Special Exposure Cohort Petitions, Rev. 0, 

National Institute for Occupational Safety and Health (NIOSH); Cincinnati, Ohio; September 23, 

2004; http://www.cdc.gov/niosh/ocas 

OCAS-TIB-0010, Best Estimate External Dose Reconstruction for Glovebox Workers, Rev. 2, 

National Institute for Occupational Safety and Health (NIOSH); Office of Compensation Analysis and 

Support (OCAS); Cincinnati, Ohio; December 30, 2005; SRDB Ref ID: 22410 

ORAU-SC&A, 2007, Draft ORAU responses to SC&A comments on the Hanford Site Profile, Oak 

Ridge Associated Universities; 2007; SRDB Ref ID: Not in SRDB 

ORAUT-OTIB-0002, Maximum Internal Dose Estimates for Certain DOE Complex Claims, Rev. 02; 

Oak Ridge Associated Universities; February 7, 2007; SRDB Ref ID: Currently not included in the 

SRDB 

ORAUT-OTIB-0030, External Coworker Dosimetry Data for the Hanford Site, Rev. 00 PC-1; Oak 

Ridge Associated Universities; November 7, 2006; SRDB Ref ID: 29961 

ORAUT-OTIB-0039, Internal Coworker Dosimetry Data for the Hanford Site, Rev. 00 PC-1; 

January, 6, 2007; SRDB Ref ID: 29969 

ORAUT-OTIB-0054 (draft), Fission and Activation Product Assignment for Internal Dose-Related 

Gross Beta and Gross Gamma Analyses; Oak Ridge Associated Universities; Draft - January 18, 

2007; SRDB Ref ID: Under OCAS review 

ORAUT-PROC-0060, Occupational Onsite Ambient Dose Reconstruction for DOE Sites, Rev. 0; Oak 

Ridge Associated Universities; June 28, 2006; SRDB Ref ID: 29986 

ORAUT-PROC-0061, Occupational X-Ray Dose Reconstruction for DOE Sites, Rev. 01; Oak Ridge 

Associated Universities; July 21, 2006; SRDB Ref ID: 29987 

ORAUT-TKBS-0006-1, Hanford Site – Introduction, Rev. 02; Oak Ridge Associated Universities; 

August 30, 2006; SRDB Ref ID: 31193 

ORAUT-TKBS-0006-2, Technical Basis Document for the Hanford Site – Site Description, Rev. 00 

PC-1; Oak Ridge Associated Universities; December 29, 2004; SRDB Ref ID: 19489 

ORAUT-TKBS-0006-3, Technical Basis Document for the Hanford Site – Occupational Medical 

Dose, Rev. 01; Oak Ridge Associated Universities; April 11, 2005; SRDB Ref ID: 19491 

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ORAUT-TKBS-0006-4, Technical Basis Document for the Hanford Site – Occupational 

Environmental Dose, Rev. 01; Oak Ridge Associated Universities; December 20, 2006; SRDB Ref 

ID: 31194 

ORAUT-TKBS-0006-5, Technical Basis Document for the Hanford Site – Occupational Internal 

Dose, Rev. 01; Oak Ridge Associated Universities; November 24, 2004; SRDB Ref ID: 19494 

ORAUT-TKBS-0006-6, Technical Basis Document for the Hanford Site – Occupational External 

Dose, Rev. 01 PC-1; Oak Ridge Associated Universities; October 5, 2006; SRDB Ref ID: 29989 

ORNL 67-3-10, Derivation of Dose Data from Hanford-DuPont Personnel Meter Exposure Records 

Applicable to the Mancuso Study, AEC Contract No. AT-(30-1)-3394, Oak Ridge National 

Laboratory, April 1967; SRDB Ref ID: 15442 

PNL-6125, Historical Review of Personnel Dosimetry Development and its Use in Radiation 

Protection Programs at Hanford, R. H. Wilson; Pacific Northwest Laboratory; February 1987; SRDB 

Ref ID: 262 

PNL-7439, A Study of Detailed Dosimetry Records for a Selected Group of Workers Included in the 

Hanford Mortality Study, E. S. Gilbert; Pacific Northwest Laboratory; 1990; SRDB Ref ID: 285 

PNL-7447, Wilson, R. H., Fix, J. J., Baumgartner, W. V., and Nichols, L. L., Description and 

Evaluation of the Hanford Personnel Dosimeter Program from 1944 through 1989, September 1990, 

SRDB Ref ID: 4793 

PNL-8909, Summary of Recorded External Radiation Doses for Hanford Workers 1944-1989, R. L. 

Buschbom; E. S. Gilbert; Pacific Northwest Laboratory; 1993; SRDB Ref ID: 299 

WHC-MR-0425, Manhattan Project Buildings and Facilities at the Hanford Site: A Construction 

History, Westinghouse Hanford Company; September 1993; SRDB Ref ID: 11572 

Cantril, 1945, Tolerance Limits, S. T. Cantril; letter to file dated October 18, 1945; SRDB Ref ID: 

13428 

Fix, 2001, Historical Hanford Radiological Record Description; J. J. Fix; E. H. Carbaugh; and J. A. 

MacLellan; Pacific Northwest Laboratory; No PNNL number assigned; July, 2001; SRDB Ref ID: 

15354 

Fix, 2007, White Paper: Evidence of Missing Hanford DuPont Dose for DuPont Workers Who Later 

Worked at SRS, Fix, J.; Oak Ridge Associated Universities; April 10, 2007; SRDB Ref. Id: 31346 

Hart, 1946, Medical Department, Health Instrument Section, Manual of Standard Procedures, 

Personnel Meters, J. C. Hart, Part 16, Film Calibration and Batch Assignments, Document No. 7­

4282, May 1, 1946; SRDB Ref ID: 15199 

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Kirklin, The AEC Health and Mortality Study: Its Purpose, Scope, and Design and the Supporting 

Data Systems from the Hanford Operations, Respective and Continuing Phases of Data Acquisition, 

C. W. Kirklin, Hanford Environmental Health Foundation, No Date Given; SRDB Ref. ID: 12330 

Pardue, 1944, Photographic Film as a Pocket Radiation Dosimeter; L. A. Pardue, N. Goldstein, and 

E. O. Wollan; CH-1553-A-2223, Metallurgical Laboratory, Chicago, Illinois; April 8, 1944; SRDB 

Ref ID: 8599 

Parker, 1986, Herbert M. Parker: Publications and Other Contributions to Radiological and Health 

Physics; Kathren, R., et al (editors); Columbus [Ohio]: Battelle Press, 1986; SRDB Ref ID: 27678 

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